Emergency action plan per 1910.38 + HAZWOPER 1910.120(q) for HHC releases
OSHA PSM 1910.119(n) requires an emergency action plan per 29 CFR 1910.38, and for facilities handling significant HHC releases, a HAZWOPER emergency response plan per 29 CFR 1910.120(q). The element covers procedures from small releases (where the employer doesn't expect to evacuate) up to credible-worst-case releases requiring full HAZWOPER response.
Emergency response capability is the difference between an incident and a catastrophe. Drill-validated capability — tabletop, functional, full-scale — is essential; plans that look good on paper but fail in real events have driven the worst process safety outcomes in history.
(n) is the resilience layer that activates when prevention fails. It integrates with (m) incident investigation through lessons-learned application, (g) training through emergency response competency, and (c) employee participation through drill engagement. The element coordinates with off-site authorities (LEPC, EPA RMP Subpart H, MSIHC Rule 14 India) for community-level response.
A focused 6-step methodology calibrated to deliver emergency planning and response as a working capability — not a documented compliance artefact.
Extract credible-worst-case from QRA / FERA / Bow-Tie; align with MSIHC / EPA RMP / COMAH threshold.
Per 1910.38, build EAP covering evacuation, accountability, rescue, medical, fire suppression, reporting.
Per 1910.120(q), build HAZWOPER ERP — pre-emergency planning, personnel roles, lines of authority, communications, evacuation, decon, PPE, training.
Per (n)(2), define procedure for releases handleable without evacuation; integrate with PTW and operations.
Tabletop (quarterly), functional (annual), full-scale (triennial); independent observer team; structured AAR.
Coordinate with LEPC / district authority; joint drill participation; off-site plan per MSIHC Rule 14 / EPA RMP Subpart H.
Decision-gated workflow showing the actual sequence of activities — from initiation through steady-state operation — with key decision points highlighted.
We can scope this element implementation against your facility, regulatory context, and existing management-system maturity — and integrate it with the other OSHA Process Safety Management (29 CFR 1910.119) elements you already operate.