Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine how to prepare for disaster situations.
We recently looked at wildfire health and safety hazards following the wildfires in Southern California. California, Oregon, and Washington have state rules addressing the health effects of wildfire smoke exposures.
The California Department of Industrial Relations (DIR) posted updated guidance for workers and employers on how to proceed rapidly and safely to address the risks associated with fire debris removal and cleanup following this winter’s wildfires. The DIR’s Division of Occupational Safety and Health (Cal/OSHA) also recently updated its guidelines for employers performing fire cleanup.
Disasters affecting the workplace include earthquakes, floods, hurricanes, and tornadoes.
However, fires limited to a facility pose their own hazards. The worst workplace disaster in New York City before the September 11, 2001, terrorist attacks was the March 25, 1911, Triangle Shirtwaist Factory fire in which 146 garment workers were killed. Fire broke out on the building’s 8th, 9th, and 10th floors, but long worktables and bulky machines hindered many workers’ escapes. The factory doors were locked to prevent theft and block labor organizers’ access. The workers, primarily young women who had recently emigrated from Europe, were trapped inside.
The building’s sole fire escape collapsed during rescue efforts. Many workers were fatally injured leaping from the building to escape the smoke and flames inside.
After the Triangle Shirtwaist fire, exit routes—means of egress—became a foundational workplace safety precaution. The Occupational Safety and Health Administration’s (OSHA) exit routes standard is among its oldest and most vigorously enforced rules.
Discount retailers have had to settle exit route violations with the agency:
- Dollar Tree Stores, Inc., the operator of discount retailers Dollar Tree and Family Dollar stores, reached a settlement agreement with OSHA in 2023, agreeing to pay $1.35 million in fines to settle contested and open alleged violations.
- Dollar General entered into a corporate-wide settlement agreement with OSHA last summer, agreeing to pay $12 million in fines and implement corporatewide changes to ensure employee safety.
- Target Corporation agreed in 2020 to pay $464,750 in penalties to resolve several cases and correct exit access and storage hazards at some 200 stores in Connecticut, Massachusetts, New Jersey, and New York.
OSHA also has regulations on emergency action and fire prevention plans. Emergency action plans detail steps you and your employees will take in the event of a fire or another emergency. When developing an emergency plan for your facility, you should consult your frontline employees, managers, supervisors, and local emergency response agencies.
Required elements of an emergency action plan include the following:
- A preferred method of reporting a fire and other emergencies;
- Your facility’s evacuation policies and plans, detailing what events trigger evacuation or sheltering in place;
- Emergency escape procedures and designated evacuation routes with floor plans, workplace maps, and safe, refuge, or post-evacuation assembly areas;
- A chain of command during emergencies with names, job titles, departments, and telephone numbers of individuals both within and outside the company to contact for additional information, along with descriptions or explanations of their duties and responsibilities under the emergency action plan;
- First-aid or medical services and rescue duties and a list of employees designated to perform them; and
- Policies and procedures for workers who must remain to shut down or continue performing critical plant operations, operate fire extinguishers, or perform other essential services to ensure others’ safety.
Workplace fire prevention plans must include:
- A list of all major fire hazards, potential ignition sources and their control, proper handling and storage procedures for hazardous materials, and the type of fire protection equipment necessary for controlling each major fire hazard;
- Procedures for controlling accumulations of flammable and combustible waste materials;
- Procedures for the regular maintenance of safeguards on heat-producing equipment for preventing the accidental ignition of combustible materials;
- The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires; and
- The name or job title of employees responsible for controlling fuel source hazards.
If your company has an emergency response team, its members must be thoroughly trained for potential disasters and need to know about any toxic hazards in the workplace. They also require training in the following:
- Use of fire extinguishers;
- First aid, including cardiopulmonary resuscitation (CPR) and self-contained breathing apparatus (SCBA);
- Compliance with OSHA’s bloodborne pathogens standard;
- Shutdown and chemical spill response procedures;
- Hazardous materials emergency response; and
- Search-and-rescue procedures.
OSHA’s emergency response proposal
Last year, OSHA released its proposed emergency response standard to replace the agency’s decades-old fire brigades standard. Fire brigades are industrial and private firefighters and emergency responders.
The proposal, if adopted, would apply to employers that have emergency response teams and emergency service organizations under contract to provide emergency medical services (EMS), firefighting, and technical search and rescue. It contains major changes to requirements for protective clothing and equipment and improvements in safety and health practices that the industry generally accepts as standard practice.
Since publication of the proposal, however, President Donald J. Trump ordered all federal agencies to remove 10 federal rules or guidance documents for every new one issued. The president also ordered agencies to compile lists of regulations for possible removal.
Hurricanes
The Atlantic and Eastern Pacific hurricane seasons are still a few months away. The Atlantic hurricane season runs from June 1 to November 30, usually peaking between August and October, according to the National Oceanic and Atmospheric Administration’s (NOAA) National Hurricane Center. The Eastern Pacific hurricane season runs from May 15 to November 30, and winter nor’easters can threaten the U.S. East Coast communities from September to April.
Hurricanes can devastate coastal businesses and communities but can move inland as tropical storms.
Do you have emergency action and evacuation plans ready for the coming hurricane season? For instance, your security staff may need to perform some search-and-rescue tasks until local emergency responders arrive.
Do you have procedures in place for recovering from storm damage? While most companies contract out recovery and cleanup activities immediately after a flood or hurricane, smaller companies may have their staff perform most cleanup tasks.
“100-year floods” keep happening with increasing regularity, as communities and employers in western North Carolina and South Carolina found during Hurricane Helene last year. It can happen “here,” wherever “here” is for you and your company.
You should consult with local government officials, fire departments, and insurance providers before a big storm hits. You may have to address issues like customer or staff casualties; damage to equipment, inventory, and structures; work disruptions; or the loss of vital documents and records.
Familiarize yourself now with the warning terms authorities use for hurricanes. Hurricane/tropical storm “watches” mean a hurricane or tropical storm is possible in your area, and hurricane/tropical storm “warnings” mean a hurricane or tropical storm is expected to reach your area, usually within 24 hours.
Have an evacuation plan to ensure workers can get out safely in case of a flood or hurricane. Evacuation procedures should have designated exits and routes and plans for evacuating disabled personnel. Your evacuation plan must address the need for those employees who must remain to continue critical plant operations. You must account for evacuated customers, personnel, and visitors.
If your emergency action plan includes a “shelter in place” option, you should stockpile emergency supplies. Preparations for sheltering in place include having enough food, water, and other supplies for each worker to last at least 72 hours.
The American Red Cross and Federal Emergency Management Agency (FEMA) have recommended supply lists. A basic disaster kit would include the following:
- One gallon of water per person per day for at least 3 days for drinking and sanitation;
- A 3-day supply of nonperishable food and a manual can opener for canned food;
- A battery-powered or hand-crank radio, such as a NOAA Weather Radio with tone alert, as well as a mobile phone with chargers and a backup battery;
- A flashlight and extra batteries;
- A first-aid kit;
- Dust masks to filter contaminated air, as well as plastic sheeting and duct tape;
- Moist towelettes, garbage bags, and plastic ties for personal sanitation; and
- A wrench or pliers to turn off utilities.
Search and rescue, recovery, and cleanup
Search and rescue should commence when a disaster hits. Recovery and cleanup begin after a fire, a flood, a hurricane, or another disaster.
Emergency responders and rescue workers may be involved in victim rescue or body recovery, as well as providing EMS.
Hazards for emergency responders and rescue workers may include exposure to asbestos or crystalline silica in damaged buildings; blood or other bodily fluids; sharp objects or jagged materials; slip, trip, and fall hazards; and even the collapse of unstable structures.
Eye, hand, foot, hearing, fall, and respiratory protection is appropriate. If cement dust or crystalline silica is present, full-face respirators with P-100 organic vapor/acid gas combination cartridges provide an appropriate level of protection from airborne contaminants that can cause eye irritation.
Recovery and cleanup after a flood or hurricane can present hazards that include carbon monoxide exposure from gasoline-powered generators; confined spaces; contaminated floodwaters; downed trees and power lines; equipment and vehicles; falls; heat stress from wearing protective clothing and working in hot, humid conditions; structural debris; and working with heavy equipment like cranes, bucket trucks, and skid-steer loaders.
Flooding can dislodge chemicals previously stored aboveground, disrupt water treatment and sewage disposal systems, and cause toxic waste sites to overflow. Floodwaters can be contaminated with fecal matter and often contain infectious organisms, including intestinal bacteria like E. coli, salmonella, and shigella; the hepatitis A virus; and typhoid, paratyphoid, and tetanus germs.
Those working in contaminated floodwaters must have hand protection and, if possible, a combination of two gloves: an inner cut-resistant glove (nitrile or a similar washable material) and an outer nitrile or latex disposable glove, preferably gloves with a thickness of between 4 and 8 millimeters.
In addition to the use of personal protective equipment (PPE), proper hygiene and sanitation are essential to minimize the spread of contaminants and disease. Where hand-washing is impractical, workers should be provided with hand sanitizer.
You need to plan now for workplace fires and other disasters before action becomes necessary. Your plans will require policies and procedures but may also require you to acquire fire protection equipment, PPE, and “shelter in place” emergency supplies.