The highest priority in a crisis is the protection of people. In its most basic form, this revolves around the choice to either move people out of danger (evacuation) or have them shelter in place. Evacuation appears simple: one simply notifies people to move out of the danger area. But like so much in life, the devil is in the details. Failing to have a sound evacuation strategy can result in an increased risk to the very people one is trying to protect. In the worst case, it can lead to unnecessary deaths.
What’s Required vs. What’s Needed
29 CFR 1910.38 Labor delineates the requirements for an Emergency Action Plan that include evacuation procedures and routes. However, the code gives you the result; it does not cover the process by which you arrive at that result. Using a fill-in-the-blanks template may help you meet code requirements, but it may not save lives when implemented. Evacuation is not just a response to fire, it is a mechanism for alerting facility occupants to a serious risk and moving them to a safer area. To be certain your plan will work, you need to develop a strategy that includes policy decisions unique to your facility and that lays out supporting mechanisms such as employee training and evacuation drills.
7 Key Points to Consider
- Assess your unique environment: There are any number of decisions that you will need to make as you develop your evacuation strategy. For example, the use of evacuation elevators in high rise buildings has been gaining in popularity after September 11th. Active shooter planning is still evolving and there is disagreement over what conditions should trigger an evacuation. Is your facility open to a large number of visitors on a daily basis? Do you serve or employ a population with functional needs such as mobility issues or cognitive, language, or physical issues that would prevent them from reacting to an evacuation announcement? Thinking out these issues and establishing sound policies beforehand provides a guide for decision makers at the time of crisis and may provide a potential liability defense.
- Identify decision makers: Some evacuations are straight forward, such as when someone activates a fire alarm. However, there are times when someone must decide between evacuation and shelter in place, such as a bomb threat or major storm. On September 11th, Rick Rescorla, the security chief for Morgan Stanley, made the decision to evacuate, despite announcements from the Port Authority to the contrary. That decision is credited with saving the lives of over 2500 Morgan Stanley employees. Who has the authority in your organization to make that kind of decision? What happens if they’re not available?
- Identify stay-behind personnel: In many facilities, there are key personnel who must remain behind after an evacuation to shut down or monitor vital processes or to assist emergency responders. If this is the case, one of the minimum requirements in 29 CFR 1910.38 is that your Emergency Action Plan include procedures for these personnel.
- Make provisions for people with functional needs: The 2000 Census noted that over 18.5 million people with disabilities are in the workforce. Some of these people may not be able to self-evacuate or to see or hear an evacuation warning. In addition, more than 20% of the US population speak a language other than English. Your evacuation plan must include procedures for alerting and assisting people with these needs.
- Choose assembly areas with care: At a meeting of several government agencies in the civic center of a major city, the attendees realized that they all had plans to evacuate to the central municipal plaza. If all the buildings were evacuated at once, the result would be chaos. In addition, since the plaza was an obvious choice for assembly areas, it would also be present a tempting target for a secondary terrorist bomb. Pick your assembly areas with care and coordinate with other facilities to avoid conflicts.
- Plan to account for everyone: One of the minimum requirements for an Emergency Action Plan is a mechanism to account for evacuees. This is normally accomplished in an assembly area by supervisors. However, many accountability plans limit themselves to employees and do not account for visitors and contract staff (e.g. janitors, repairmen). People with functional needs are sometimes overlooked as well. Accountability must extend to anyone within the facility and must consider those working off hours as well.
- Conduct realistic exercises: There is a lot of resistance to evacuation drills. They can be costly in terms of lost productivity. For this reason, they tend to be infrequent and held to the absolute minimum of effort. However, they are absolutely vital. One of the reasons for the survival of the Morgan Stanley employees on September 11th was the frequent exercises insisted upon by Rick Rescorla. These were full evacuation exercises (Morgan Stanley was located on the 72nd floor) and included any visitors. The frequency and intensity of these exercises meant that employees knew the evacuation routes and were trained to evacuate quickly.
Far from being simple, an evacuation plan requires considerable thought. The actual movement of people out of the facility is the easy part. But it will only be easy if you take the time and effort to develop a sound strategy to support it.
This article is brought to you by TAL Global’s Mr. Lucien G. Canton – Managing Director, Emergency Preparedness.
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