Friday, September 16, 2016

Safety Tidbit #2.7 – Emergency Alarm Systems


Safety Tidbit #2.7 – Emergency Alarm Systems

Source:            29CFR1910.38 Emergency Action Plans
29CFR1910.165 Employee Alarm Systems

I received a call from a client yesterday asking for guidance on alarms for use in their business to let workers know to evacuate.  I quickly answered the question by pointing to OSHA’s 1910.38 on Emergency Action Plans (EAP) and said that not all areas are candidates for audible alarms.  He mentioned about using an industrial shredder to grind and recycle plastic in one particular work area.  I explained that a visual signal might be more appropriate in that space.  He was satisfied, and we hung up from each other.  Upon further reflection, I realized that I only gave him half of the OSHA standards neglecting 1910.165, specifically on alarm systems altogether. So to make up for my oversight I used his question as the topic for this week’s Safety Tidbit.

We are all aware that OSHA requires a written emergency action plan in the workplace, and available to employees for review. With the proviso that employers with 10 or fewer employees may communicate their plan orally. The minimum requirements for an EAP are:

    Procedures for reporting a fire or other emergency
    Procedures for emergency evacuation, including type of evacuation and exit route assignments
    Procedures for employees to follow who remain to operate critical plant operations before they evacuate
    Procedures to account for all employees after evacuation
    Procedures for employees performing rescue or medical duties
    List of employees responsible for the emergency plan

All these items are crucial. However, they don’t make a difference if the workers actually can’t tell when they need to evacuate or take emergency action.  Therefore, it is in 1910.38(d) that we get to the “how” of the matter. This section requires an employer to have and maintain an employee alarm system. The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in 1910.165 which, leads us to Part II of my answer that I initially neglected to tell my client.

As stated in OSHA’s 1910.165, the employee alarm system shall provide a warning for necessary emergency action as called for in the company's emergency action plan, or for reaction time for safe escape of employees from the workplace or the immediate work area, or both.

Ultimately, employees must be able to perceive the alarm above ambient noise or light levels in the affected areas of the workplace, which was what I was describing to my client in the grinder room where the ambient noise can reach 105 decibels. Interestingly, OSHA mentions physical devices which may be used to alert those employees who would not otherwise be able to recognize the audible or visual alarm. Furthermore, the alarm shall be distinctive and recognizable as a signal to evacuate the work area or to perform actions designated under the emergency action plan. For more information, please check out OSHA’s eTool on Evacuation Plans and Procedures.

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan
http://safety-tidbits.blogspot.com/

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