How to Conduct Hazard Assessments Before Creating Emergency Action Plans

Written By Jon Anna

A well-designed Emergency Action Plan (EAP) begins long before the first page is written. The foundation is a thorough hazard assessment—a structured process to identify, analyze, and control the risks that could lead to an emergency. Below is a step-by-step guide to building a compliant, practical, and continuously improving EAP program.

1. Start With a Comprehensive Hazard Assessment

Define the Scope

Identify all operations, locations, and processes that could create emergencies: fire, chemical release, severe weather, workplace violence, utility failures, etc. Include non-routine tasks such as maintenance shutdowns and contractor activities.

Build the Right Team

Involve people who know the work best:

  • Safety/EHS professionals (lead the process, ensure regulatory alignment)

  • Operations and maintenance staff (understand day-to-day hazards)

  • Supervisors and line employees (know practical controls and workflow realities)

  • Facilities and security (infrastructure, access, and building systems)

  • Management (authority to allocate resources and approve corrective actions)

2. Key Documents and Data Sources

Gather and review:

  • OSHA 29 CFR 1910 Subpart E & 1910.38 (EAP requirements)

  • Prior incident reports, near-miss records, and OSHA 300 logs

  • Process safety information, P&IDs, and equipment manuals

  • Building and site drawings, fire alarm/sprinkler documentation

  • Local emergency services contact information and community hazard plans

  • Insurance risk-control reports and third-party audits

3. Choosing and Applying Risk Assessment Methods

Select one or two methods that match your operations and use them as the bridge to your EAP. Here’s how:

  • Job Hazard Analysis (JHA)
    Use it to map task-by-task hazards, then feed the highest-severity tasks into EAP procedures.
    Example: A JHA reveals flammable solvent transfer as high risk. The EAP must include a fire-evacuation protocol specific to that transfer area and name who shuts off pumps.

  • Failure Modes & Effects Analysis (FMEA)
    Score equipment or process failure modes, then translate high-severity/high-occurrence scores into EAP scenarios.
    Example: An FMEA flags a refrigeration compressor rupture as critical. Your EAP needs ammonia-release evacuation routes and a designated spill response.

  • Hazard and Operability Study (HAZOP)
    Identify process deviations and use the guide-word findings to define incident types for the EAP.
    Example: A “low flow” HAZOP deviation suggests possible reactor overheating. Build specific alarm and shutdown steps into the EAP.

  • Risk Matrix or Semi-Quantitative Scoring
    Quickly rank hazards; the “high” quadrant becomes your prioritized EAP event list.
    Example: A severe storm hazard scoring “High” triggers an EAP severe-weather shelter plan.

  • Bow-Tie Analysis
    Visualize threats, barriers, and consequences. Each consequence path becomes an EAP scenario with required barriers as pre-incident controls.

The key is to document the handoff: keep a simple “Hazard-to-EAP” matrix or log that lists each significant hazard, the chosen assessment method, and the exact EAP section or procedure that addresses it.

4. Make It an Ongoing Cycle

Hazard assessments aren’t a one-and-done exercise. Establish a schedule and triggers for re-evaluation:

  • Annual or biennial reviews

  • After significant changes (new equipment, process change, construction)

  • Following incidents or near misses

  • When new regulatory requirements emerge

Document each review, update risk scores, and track corrective actions to maintain continuous improvement.

5. Developing the Emergency Action Plan

Once hazards and risk levels are clear, create the EAP around the specific scenarios you identified.

Essential Components

  • Emergency reporting and alarm procedures

  • Evacuation routes and assembly areas (with maps)

  • Roles and responsibilities (incident commander, floor wardens, first aid, etc.)

  • Shutdown procedures for critical equipment

  • Rescue/medical duties

  • Communication methods (internal alerts, public information)

  • Coordination with outside responders (fire, EMS, hazmat teams)

Level of Specificity

Your plan should be site-specific and action-oriented. Avoid generic language; use clear instructions (“Pull the red lever labeled ‘Main Gas Shutoff’”) rather than vague directives (“Turn off utilities if safe”).

6. Documenting and Using the Plan

  • Format: A single, controlled document or digital portal with version control.

  • Distribution: Provide printed copies in key locations and digital access for remote staff.

  • Training: Conduct initial and refresher training; use tabletop drills and full-scale exercises.

  • Integration: Align with business continuity, security, and local emergency response plans.

7. Keeping the Plan Fresh

  • Annual Review: Verify contacts, floor plans, and procedures.

  • Drills and After-Action Reports: Use each exercise or real event to capture lessons learned.

  • Change Management: Tie EAP updates to your Management of Change (MOC) or similar system so facility or staffing changes automatically trigger a review.

Key Takeaway

A robust Emergency Action Plan is only as strong as the hazard assessment behind it. By engaging a cross-functional team, leveraging proven risk assessment methods, and explicitly mapping those risk findings to EAP procedures, organizations can create plans that protect employees, satisfy OSHA requirements, and remain ready for the unexpected.

Jon Anna
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