Guidelines for OSHA Compliance During Hurricane Season

Everyone should be prepared for an emergency. but federal law requires that employers provide a safe work environment even in the face of a natural disaster. Consequently, employers — particularly those in areas most affected by hurricanes — need an emergency-action plan to ensure workers are safe and prepared to handle the drastic changes in workplace conditions that can result from a hurricane, storm or other natural disaster.

Hurricane season in the Atlantic runs from June to November. The Eastern Pacific hurricane season lasts from mid-May through November.

Hurricanes are strong storm systems with sustained wind speeds of 74 miles per hour or higher, capable of causing devastating damage. Those charged with dealing with the aftermath of such storms face significant challenges — such as downed power lines and trees and large amounts of construction debris — on top of their normal tasks.

Organizations must undertake appropriate risk assessments to properly identify, evaluate, control and eliminate the anticipated occupational hazards and health risks to employees working in hurricane-impacted areas. Developing a detailed plan of action is critical to ensure the necessary equipment is available and policies and procedures are in place so employees know where to go and how to stay safe while carrying out their duties.

The Occupational Safety and Health Administration (OSHA) offers four general guidelines for developing an effective and OSHA-compliant emergency-action plan:

  1. Written and Oral Communication. An emergency-action plan must be put in writing and easily accessible by everyone in the workplace. Copies should be available in the facility as well as with employee handbooks or human resource materials. Employers with fewer than 10 employees may communicate the action plan verbally.
  2. Minimum Requirements. OSHA regulations require that all emergency- action plans include the following items:
    • Fire safety and reporting procedures;
    • Evacuation plans, including routes;
    • Methods for accounting for employees after evacuations;
    • A list of employees assigned to stay behind during evacuations;
    • Procedures for employees during rescue-and-medical emergencies; and
    • Emergency contact information for employees to learn more about procedures.
  3. Alarm Systems. Employers must install and maintain a proper alarm system with separate and distinct sounds for all types of emergencies including lockdowns, evacuations and fires. Employees who require access to the system should be appropriately trained, and on-site drills should be conducted to familiarize employees with the alarm system.
  4. Training and Review. Employers should review safety plans with all employees and train them to assist during an emergency in a safe and orderly way. Training should be carried out whenever changes are made to the plan or a new employee joins the organization. Temporary employees must also be made aware of emergency plans.

Hurricanes can be devastating, but employers can help minimize the impact with proper preparation. Workers performing tasks under the adverse conditions of response-and-recovery work must be trained in job-specific safety procedures and in the safe use of tools, machinery and personal protective equipment (PPE).

Failing to provide OSHA training not only increases the risk of injury during a hurricane response, but subjects the employer to OSHA scrutiny and penalties for noncompliance.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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