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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 Regulation
29 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