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System-wide Risk Management Plan - EHS: Egress

Lori Ranzino Renda

MET AD 613: system-Wide Risk, Security, and Compliance

David Byrne & Mike Jennings

June 1, 2013

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Environmental Health & Safety (EH&S) in not an industry so to speak, but rather EH&S

is a pillar of all industry, which when approached systematically creates a successfully safe

workplace. Contain herein is a system-wide risk management plan for emergency egress and the

regulatory compliance standards for such a plan. With the help of OSHA guidelines included

will be methods and best practices promoted by OSHA.

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Challenges

System-wide risk management planning takes a commitment and the endorsement of

senior-level management. The commitment must last past the initial announcement of the

program and be carried through with the implementation of a corporate campaign promoting the

risk plan initiative. Integration of the old and the new will be a woven tactfully into the new

program processes (Barton, Shenkir & Walker, 2002). Risk management will not guarantee

failure. Failure associated with risk management result from using a risk metric that made the

wrong enquiries. In order for an industry to grow it must take risks. The relationship between

EH&S and operations is binding in that one cannot exist without the other (SAI-Global, 2013).

A good EH&S risk management program will require a look into the business to identify

the probability of risks in connection with each process of a particular job or job function. The

areas in question are, (i) what are the risks; (ii) who or what is at the highest risk; (iii) which

stakeholder is at risk; (iv) what are the foreseeable risks; and (v) are the risks preventable? (Noth,

2013). The answers to these questions will become the foundation of the mitigation plan

(Barton, et al, 2002). Risk assessment involves the integration of the threat, the vulnerability,

and the resulting outcomes (Noth, 2013). The purpose of these types of reviews is to find

vulnerabilities and to take appropriate proactive measures to limit the consequences of an issue.

The threats associated with egress are explained in the next section.

Risk Assessment: Egress

Egress as defined is, "The act of coming or going out; emergence. The right to leave or

go out: a path or opening for going out; an exit…" (Merriam Webster, 2013). The plan must

meet the following compliance guidelines per OSHA Regulations form the U.S. Department of

Labor, Occupational Safety and Health Administration General Industry Regulations and are as

follows:

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Egress Metric Risk Assessment Regulation29 CFR 1910 Subpart E

Compliance Action

What are the risks?

Are exit routes clearly marked?

Are the exits routes permanent?

A risk assessment will entail physical assessment of all exit areas from all buildings.

"EXIT" signs must be in place and illuminated at all times. This does not pertain to mobile workplaces such as vehicles and vessels (OSHA E-1).

Hard wire electricity must be at each point of egress to meet compliance standards.

1910.33-39

1910.34-39-Cover the minimum requirements per exit routes that employers must provide in their workplace so the employees may evacuate the workplace safely during and emergency. 1910.34- alternating current excites phosphor atoms when placed between the electrically conductive surfaces to produce light

1910.36 (a)(1)- Each exit route must be a permanent part of the workplace.

Placement of EXIT signs throughout all buildings at all exit areas.

Electroluminescent lighting will be installed at every exit throughout the enterprise.

EXIT sign must be supplied with a light-emitting capacitor. Procurement of OSHA compliance EXIT signs from a third party vendor.1910.36 (a)(1)- Each exit route must be a permanent part of the workplace.

Identify who or what is at the highest risk?

All employees, vendors, customers, visitors, senior management, and firefighters are all at risk in time of fire.

Which stakeholder is at risk?

All stakeholders are at risk of death if egress is not properly marked at the time of fire.

What are the foreseeable risks?

The foreseeable risks are associated with life and death.

Are the risks preventable?

Yes, the risks associated with egress are preventable.

OSHA compliance guidelines found in Section E of the OSHA General Industry Regulations from the U.S. Department of Labor, Occupational Safety and Health Administration, revision April 2013.

As found in the above mentioned items.

Figure 1: Risk Assessment Metric and OSHA Compliance Guideline Responses

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Risk Planning: Egress

The system-wide plan for egress from buildings will follow OSHA compliance

guidelines as found in the General Industry Regulations Handbook. For an organization to be in

compliance a Risk Assessment most be completed at each location and at each exit area of the

building. Only actual exits will be considered for marking. The following is the plan for

evaluating and implementing proper egress notification. Each entrance will become an exit at

some point. Each exit will be clearly marked with a hardwired EXIT sign purchase for a good

and reliable source. In case of power failure the EXIT sign must be able to generate its own

power (through a battery) to remain lite for one-hour in a three or fewer stories building, if the

building is four or more stories the EXIT sign must remain lite on its own power for two-hours

In order to meet OSHA compliance standards all entrance and exits will have electrical

power brought to the area to be able to sustain permanent placement of the EXIT signage. The

following emergency action plan follows.

Emergency Action Plans: OSHA §1910.38(a)

An employer must have an emergency action plan for each standard in the OSHA

regulation calling for one (OSHA, 2013).

Written or Oral Emergency Plan: OSHA §1910.38(b)

These emergency action plans are required to be in writing, but can be in an oral

presentation as well if there are less than 10 employees. The emergency action plan must be

made available to all employees (OSHA, 2013).

Procedure for Reporting a Fire: OSHA §1910.38(c)(1)

The procedure for reporting a fire is to call 911 and then notify security.

Procedure to Evacuate: OSHA §1910.38(c)(2)

All emergency response team members will consist of EH&S personnel. Each

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emergency response team members will help to move people outside the building and will

remain in each area until all others have been evacuated. All evacuation will be in an orderly

fashion and no one is to run at this time. Each emergency response team member will report to

team leader as the evacuation process progresses. All employees will be evacuated via the

stairways; no one will leave via elevation.

Egress assignments are for all employees to follow; employees must follow "Fire Exit"

signage posted near all exits. Third floor employees will exit via the staircase located on the

"east side" of the building, once on the first floor exit out the front doors. Second floor

employees exit via the staircase located on the 'east side' of the building, at the first floor level

exit out the front doors and first floor employees till exit out the front door of the building.

Critical Evacuation Plan for Emergency Response Team Members: OSHA §1910.38(c)(3)

Emergency response team member will evacuate via the stairways after each floor has

been cleared for any and all occupants. Evacuation will be done in an orderly fashion and will

be done in an expedited fashion.

Accounting for Employees: OSHA §1910.38(c)(4)

After all employees have evacuated the building he or she will report to the emergency

team leader. This person will be wearing a BLUE baseball cap with the words "emergency

Team Leader" Written on the front of the cap. Employees will report manager's name,

department, and any other information he or she may deem necessary.

Procedures for Rescue & Medical Volunteers: OSHA §1910.38(c)(5)

All rescue and medical volunteers will report to the Incident Commander for assignment.

The Incident Commander will be wearing an ORANGE baseball cap with the words "Incident

Commander" written on it. All rescue employees and medical volunteers are required to have

American Heart Association first-Aid, CPR-AED training and a valid certification on file in the

EH&S office.

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Contact Names: OSHA §1910.38(c)(6)

A list of all employees, his or her department, and his or her contact phone number; this

list be kept up-to-date.

Employer Alarm System: OSHA §1910.38(d)

The alarm system is located on each floor near the fire exit along with the fire pull. The

alarm system will be activated immediately at any sign of fire.

Training: OSHA §1910.38(e)

Fire evacuation training will be held every six months; employees will perform a fire

drill; all employees will take on their emergency management roles during drill sessions. The

Incident Commander will time the training session and keep a report in the EH&S office for

auditing processes.

Review of Emergency Action Plan: OSHA §1910.38(f), (f)(1), (f)(2)

The EH&S personnel will review this emergency action plan with all employees.

Documentation of this training is mandatory and will be kept in the EH&S office. The plan will

be reviewed at the time an employee hires on, at the time an employee changes jobs, and when

the plan is revised.

Costs Associated With Implementing

The costs related to implementing a fire and egress action plan to remain compliant with

OSHA is dependent on the location, vendor pool, signage needed and size of the organization.

EH&S team is responsible for the implementation processes. Cost for signage will be a part of

the construction budget.

The cost related to this type of personnel is dependent on the person, years of experience,

and company's employment budget.

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Applying the Methods and Practices

The application of the Emergency Risk Management Plan is dependent on the OSHA

standard of compliance. The methods and practices must meet the OSHA standard for

emergency action planning. These methods and practices can be found in the OSHA General

Industry Regulations Handbook. EH&S will always make available the regulation handbook for

all employees to read as deemed necessary to meet compliance standards.

Most Important Aspects of the Process

The most important aspects of the process is based on the commitment of senior

management in support of the plan as mentioned above herein. The other important component

of the process is the application of EIXT signage and the adherence to the emergency action plan

for fire reporting, egress, and processes after the fact.

Ensure That the Plan is Meaningful and Effective

Because EH&S always follows OSHA compliance guidelines the Emergency Action Plan

is a meaningful plan and will be effective if followed as prescribed herein.

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In conclusion, Environmental Health & Safety (EH&S) is respected as a pillar of all

industry, which when approached systematically creates a successfully safe workplace. Contain

herein is a system-wide risk management plan for emergency egress and the regulatory

compliance standards for such a plan. With the help of OSHA guidelines included will be

methods and best practices promoted by OSHA. Included is the Emergency Action Plan

developed by EH&S for the safety of all employees.

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References

Byrne, D., (2013). Lecture week three. System-wide Risk Planning, Strategies, and

Compliance. Boston University.

Barton, T. L., Shenkir, W. G., & Walker, P. L., (2002). Conclusion. Making Enterprise Risk

Management Payoff: How Leading Companies Implement Risk Management (p.221).

Prentice Hall PTR. Upper Saddle River, NJ

Noth, M., 2013). EH&S Risk Management. SAI-Global. Retrieved from http://www.saiglobal.

com/thankyou/?link=%2fcompliance%2fresources%2fwhitepapers %2fSAI-GLOBAL-

whitepaper-ehs-risk-management.pdf&linktext=Continue+download+now&ProspectPage

ID=16093&mtc

OSHA, (2013). Exit routes and emergency planning. General Industry Regulations (pp.E1-E4).

National Safety Compliance, Inc. Springfield, MO