Emergency Action Plans and Workplace First Aid: Requirements and Setup

OSHA 1910.38 requires an emergency action plan covering emergency reporting, evacuation routes, headcount procedures, rescue or medical duties and contact details; it must be written if you have more than 10 employees. Workplace first aid under 1910.151 requires trained responders when no clinic or hospital is in near proximity, with kits guided by ANSI/ISEA Z308.1.

Workplace emergencies are not limited to fires. A serious injury, chemical splash, power outage, severe weather event, medical incident or evacuation can quickly expose whether a workplace has a plan people can actually follow.

For US employers, managers, HR teams and supervisors, emergency preparedness is not only about having a document in a binder. It is about knowing who reports the emergency, how people evacuate, where they assemble, who checks headcount, where first aid supplies are located and who is trained to respond.

This guide explains emergency action plan requirements, workplace first aid requirements, first aid kit expectations and practical setup steps for US workplaces. For broader safety context, read Workplace Safety 101: The Complete Guide to HSE Fundamentals (2026).

Key facts: OSHA emergency action plan and first aid requirements

Featured Course

HSE Fundamentals for All Employees

Build practical emergency preparedness knowledge with structured workplace safety training from GSA.

Explore Course →

When you legally need an EAP and when it must be written

An emergency action plan, or EAP, is a workplace document that explains what employees and designated responders should do during emergencies. OSHA describes an EAP as a written document required by particular OSHA standards. The purpose is to organize employer and employee actions during workplace emergencies.

A common mistake is assuming that every employer automatically needs a written EAP solely because it has employees. OSHA 1910.38 is more specific: an employer must have an EAP whenever an OSHA standard in that part requires one. The employer must then follow the requirements of 1910.38.

A required EAP must be:

• Written

• Kept in the workplace

• Available to employees for review

However, employers with 10 or fewer employees may communicate the plan orally instead of keeping a written plan.

That does not mean smaller workplaces should avoid documentation. Written procedures are usually easier to train, review and update, especially when shifts, visitors, contractors, remote workers or multiple supervisors are involved.

US employers should also remember that emergency planning may connect with other safety topics such as fire prevention, hazardous chemicals, PPE, alarm systems, exit routes, severe weather and first aid. If your organization uses different safety terminology, the guide HSE vs EHS vs OHS vs SHE: What Do They Mean and What's the Difference? can help clarify how those terms are used.

The 6 mandatory EAP elements 1910.38(c)

OSHA 1910.38(c) sets out the minimum elements that must be included in an emergency action plan.

A strong EAP should go beyond minimum wording. It should be site-specific, easy to follow and practical for the real workforce. For example, an office, warehouse, dental clinic, restaurant, construction-related office and manufacturing site will not have identical risks.

Employers should also monitor current OSHA requirements through OSHA Law & Regulations, especially when operations, hazards or employee duties change.

Building evacuation maps and assembly points that work

Evacuation maps are most useful when employees can understand them quickly under pressure. A map that looks good on paper but does not match the workplace layout can create delay and confusion.

A practical evacuation map should show:

• Primary and secondary exits

• Exit routes from each main work area

• Stairwells and accessible evacuation routes

• Fire alarm pull stations where relevant

• Fire extinguisher locations where employees are trained or expected to use them

• First aid stations and AED locations if provided

• Assembly points outside the building

• Areas where visitors, contractors or customers may be present

Assembly points should be far enough from the building to avoid smoke, falling glass, traffic, emergency vehicle access routes and other hazards. They should also be simple to describe, such as “north parking lot by the blue sign,” not “outside near the road.”

For headcount, assign clear responsibility. One person should not be expected to manage every task. A stronger system may include:

For multi-shift workplaces, every shift needs coverage. A plan that only works when the safety manager is present during normal office hours is incomplete.

First aid duty: the near proximity rule 1910.151

Workplace first aid requirements are covered under OSHA 1910.151. The standard requires employers to ensure ready availability of medical personnel for advice and consultation on matters of plant health. It also states that where no infirmary, clinic or hospital is in near proximity to the workplace for treating injured employees, a person or persons must be adequately trained to render first aid.

The phrase “near proximity” is important. OSHA interpretation letters explain that emergency care should generally be available within 3–4 minutes where serious injuries such as stopped breathing, cardiac arrest, uncontrolled bleeding, falls, suffocation, electrocution or amputation are possible. In lower-risk workplaces such as offices, OSHA has recognized that up to 15 minutes may be reasonable in some cases.

For employers, the practical question is not simply “Is there a hospital nearby?” It is:

• Can emergency care realistically reach the injured employee quickly enough?

• Are there serious injury risks in the workplace?

• Are employees working alone, remotely, outdoors, at night or across a large site?

• Do trained first aid responders cover all shifts?

• Are first aid supplies accessible without crossing multiple locked doors, stairways or remote corridors?

A low-risk office may have different first aid needs from a warehouse with forklifts, a kitchen with burn risks, a laboratory with corrosive chemicals or a maintenance team using powered tools.

First aid kits: ANSI Z308.1 Class A vs B

OSHA 1910.151(b) requires adequate first aid supplies to be readily available. OSHA Appendix A to 1910.151 is non-mandatory, but it refers to ANSI Z308.1 as an example of minimum first aid kit contents for a generic small worksite.

The current commonly used workplace kit standard is ANSI/ISEA Z308.1-2021, published by the International Safety Equipment Association. ISEA states that ANSI/ISEA Z308.1-2021 is a voluntary industry consensus standard establishing minimum performance requirements for first aid kits and supplies.

Class A kits are designed for common injuries such as minor wounds, abrasions, minor burns and eye injuries. Class B kits include a wider range and greater quantity of supplies and are better suited to more complex or higher-hazard environments.

Employers should not choose a first aid kit by headcount alone. OSHA has stated that kit needs should be assessed by workplace-specific hazards, likely injuries, worksite size, multiple operations, injury logs and consultation with appropriate medical or emergency-response resources where useful.

A practical first aid kit program should include:

• Kit class selection based on workplace risk

• Kit placement near work areas, not only in a locked office

• Monthly checks or checks after use

• Replacement of expired, damaged or used supplies

• Clear signs showing kit locations

• PPE for responders where blood or body fluid exposure is reasonably anticipated

• Additional supplies for burns, chemicals, outdoor work, remote teams or severe bleeding where risk assessment supports it

When first aid response may involve gloves, eye protection, face shields or body-fluid exposure, connect your first aid setup to PPE planning. See Types of PPE: The Complete Guide to Personal Protective Equipment.

AEDs, eyewash stations and special hazards

AEDs, eyewash stations and special emergency equipment should be considered separately from basic first aid kits.

Is an AED required by OSHA?

OSHA 1910.151 does not generally require AEDs to be included in first aid supplies. OSHA has stated that the medical services and first aid standard does not specifically require AEDs as first aid supplies.

However, an AED may still be appropriate for risk management, workforce health, large sites, remote locations, high-occupancy buildings, fitness areas, older worker populations or locations where emergency medical services may not arrive quickly. Employers should also check state and local requirements, because AED rules may apply in specific settings.

If an AED is provided, the workplace should define:

• Where it is located

• Who checks it

• Who is trained to use it

• How pads and batteries are replaced

• How AED use is coordinated with 911 and CPR response

When are eyewash stations required?

OSHA 1910.151(c) requires suitable facilities for quick drenching or flushing of the eyes and body where a person’s eyes or body may be exposed to injurious corrosive materials.

This is especially relevant for workplaces with:

• Corrosive cleaning chemicals

• Battery charging areas

• Laboratories

• Chemical mixing

• Maintenance operations

• Food processing sanitation chemicals

• Industrial production chemicals

Chemical hazards should also be linked to labels, pictograms and Safety Data Sheets. For a related guide, read Hazard Communication and GHS: Labels, Pictograms and SDS Explained.

What special hazards should be added to the plan?

The EAP and first aid setup should reflect the workplace’s actual hazards. Examples include:

International readers should check local first-aid laws. For example, the UK HSE explains that the Health and Safety (First-Aid) Regulations 1981 require employers to provide adequate and appropriate first-aid equipment, facilities and personnel based on workplace circumstances.

Featured Course

HSE Fundamentals for All Employees

Help employees and supervisors understand emergency procedures, first aid responsibilities and workplace safety fundamentals.

Explore Course →

Training and drilling the plan

A written EAP is not enough. OSHA 1910.38 requires employers to designate and train employees who assist in a safe and orderly evacuation. It also requires employers to review the EAP with covered employees when the plan is developed or the employee is initially assigned to a job, when the employee’s responsibilities under the plan change and when the plan changes.

Training should cover:

• How to report emergencies

• Alarm sounds and communication methods

• Evacuation routes and exits

• Assembly points

• Headcount process

• Who has emergency roles

• What employees should not do

• First aid responder contacts

• Visitor and contractor procedures

• Shelter-in-place instructions where relevant

Drills should be practical and reviewed afterward. A short debrief can reveal blocked exits, unclear assembly points, outdated contact lists, missing shift coverage or poor visitor accounting.

A simple improvement cycle works well:

1. Write the plan.

2. Train employees and supervisors.

3. Equip the workplace with first aid supplies and emergency tools.

4. Drill the procedure.

5. Document attendance, issues and corrective actions.

6. Review after changes, incidents or exercises.

This aligns with the broader management-system idea in ISO 45001, which provides a framework for managing occupational health and safety risks. The ILO also frames occupational safety and health as a workplace-level responsibility involving prevention, systems and worker protection.

According to the US Bureau of Labor Statistics, private industry employers reported 2.5 million nonfatal workplace injuries and illnesses in 2024, with a total recordable case rate of 2.3 cases per 100 full-time equivalent workers. This does not mean every workplace faces the same risks, but it does show why emergency preparedness, first aid readiness and employee training remain operational priorities.

Example: emergency preparedness setup for a small workplace

A 35-person office and operations facility could set up its emergency preparedness system like this:

This example is not a universal template. It shows the level of detail that makes an emergency plan usable in real life.

Conclusion

Emergency action plan requirements are most useful when they become practical workplace habits. A strong EAP explains how employees report emergencies, evacuate safely, account for people, support rescue or medical duties and contact the right person for plan guidance.

Workplace first aid should be connected to the same system. Employers should assess response times, first aid coverage, kit contents, AED decisions, eyewash needs, special hazards, training records and drill outcomes.

For US workplaces, the strongest approach is simple: write the plan, train the team, equip the site, drill the process, document the results and review it whenever work changes.

Featured Course

HSE Fundamentals for All Employees

Strengthen workplace safety awareness and receive a Certificate of Completion from Global Safety Academy after completing the course.

Explore Course →

Continue Reading

• Workplace Safety 101: The Complete Guide to HSE Fundamentals (2026)

• HSE vs EHS vs OHS vs SHE: What Do They Mean and What's the Difference?

• Types of PPE: The Complete Guide to Personal Protective Equipment

• Hazard Communication and GHS: Labels, Pictograms and SDS Explained

Author Byline

Written by the GSA Editorial Safety Team for Global Safety Academy. GSA develops professional online training content for learners, employers, managers, supervisors, HR teams, compliance teams and workplace safety professionals.