Audit, Compliance and Risk Blog

OSHA Provides Planning and Response Advice Addressing Hurricanes

Posted by Jon Elliott on Tue, Sep 25, 2018

FloodingFederal agencies have marked the beginning of Atlantic hurricane season by reminding employers and the public of the risks from hurricanes, and how to plan for and respond to events. These include a compilation of advisory documents on the Occupational Safety and Health Administration (OSHA) website, which also includes links to additional information by the Federal Emergency Management Agency (FEMA), Centers for Disease Control and Prevention (CDC), and the National Hurricane Center. This information is too late to help people in the Carolinas who’ve been inundated by Florence, but does provide useful reminders.

Hurricane Hazards

The principle immediate hazards from hurricanes are high winds and driving rain, with risks of severe injuries and drowning. Longer term hazards including site flooding and complications from power loss and transport cutoffs, which can limit access to medical care and allow for additional injuries and illnesses.

  • Hurricane Categories

The five official hurricane Categories are based on sustained windspeeds, with damage warnings calibrated to the impacts of those winds.
  1. Winds 74-95 miles per hour (mph) – chance of damage to well-constructed buildings, some tree toppling, likely power outages.

  2. Winds 96-110 mph -- chance of major damage to well-constructed buildings, likely extensive tree toppling, likely extensive and lengthy power outages.

  3. Winds 111-129 mph – likely major damage to many well-constructed buildings, likely extensive tree toppling, likely extensive and lengthy power and water outages.

  4. Winds 130-156 mph -- chance of catastrophic damage to well-constructed buildings, likely extensive tree toppling, likely extensive and lengthy power outages, with some built-up areas isolated and possibly uninhabitable for weeks or months.

  5. Winds 157 mph or higher – extensive catastrophic damage with chance of major damage to well-constructed buildings, likely extensive tree toppling, likely extensive and lengthy power outages, with built-up areas extensively isolated and possibly uninhabitable for weeks or months.

Stay mindful that wind conditions can change drastically through the course of a storm event. In 2005, for example, Hurricane Katrina hit land as a Category 3 storm, but had accelerated to Category 5 by the time it devastated New Orleans. In contrast, in 2018 Hurricane Florence peaked at Category 4 before diminishing to Category 1 before hitting the Carolinas, and later weakening further from hurricane to tropical storm to tropical depression.

  • Rainfall and Flooding

These wind-based categories do not provide explicit consideration of precipitation, and the subsequent risks of flooding. Florence provides a reminder that slower-moving hurricane systems may linger over particular areas longer, increasing the likelihood of flooding even if the wind-based category is lower.

What Preparedness Activities Does OSHA Recommend?

OSHA recommends that employers in hurricane-prone areas do all of the following:
  • Sign up for community warning systems, and know warning terms used for hurricanes

  • Know the local community's emergency plans, warning signals, and shelters

  • Prepare to respond to events – with onsite evacuation plans and preferably with Emergency Action Plans (EAPs) that meet OSHA criteria.

  • What Should Hurricane Evacuation Plans Include?

OSHA’s hurricane preparedness guidance recommends that employers’ evacuation plans include the following elements:

  • Conditions that will activate the plan

  • Chain of command

  • Emergency functions and who will perform them

  • Specific evacuation procedures, including routes and exits

  • Procedures for accounting for personnel, customers and visitors

  • Equipment for personnel

These can readily be integrated into broader EAPs.

  • What Do EAPs Require?

OSHA’s EAP Standard requires you to include at least the following elements:

  • Preferred methods for reporting fires and other emergencies

  • Emergency escape procedures, including different evacuation scenarios

  • Emergency escape route assignments for employees (OSHA provides separate standards for “exit routes”)

  • Procedures for employees assigned to operate critical plant operations before they evacuate

  • Procedures to account for all employees after emergency evacuation

  • Rescue and medical duties and procedures for designated employees

  • Names or regular job titles of persons or departments to contact for further information or explanation of duties under the plan.

OSHA’s advice for preparation builds on its general recommendation that all employers create Emergency Action Plans (EAPs) addressing recognized hazards (some OSHA standards require subject employers to have EAPs; I wrote about these here).

  • What Should Onsite Emergency Kits Contain?

OSHA passes along recommendations from FEMA that workplaces have emergency kits, including sufficient resources for at least 24 hours of sheltering in place in case evacuation routes are unavailable. FEMA recommends the following kit, for homes and workplaces:

  • Water - one gallon of water per person per day for at least three days, for drinking and sanitation

  • Food - at least a three-day supply of non-perishable food

  • Battery-powered or hand crank radio and a NOAA Weather Radio with tone alert

  • Flashlight

  • First aid kit

  • Extra batteries

  • Whistle to signal for help

  • Dust mask to help filter contaminated air and plastic sheeting and duct tape to shelter-in-place

  • Moist towelettes, garbage bags and plastic ties for personal sanitation

  • Wrench or pliers to turn off utilities

  • Manual can opener for food

  • Local maps

  • Cell phone with chargers and a backup battery

Larger facilities presumably have more complexity and can muster more resources.

Self-Assessment Checklist

Does the organization own or operate any facility in areas prone to hurricanes?

If so, has the organization established hurricane preparedness and response plans for each such facility?

Where Can I Go For More Information?

- Emergency kit webpage 

Specialty Technical Publishers (STP) provides a variety of single-law and multi-law services, intended to facilitate clients’ understanding of and compliance with requirements. These include:

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About the Author

Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 25 years. He was involved in developing Environmental Compliance: A Simplified National Guide and The Complete Guide to Environmental Law.

Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).

Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).

You may contact Mr. Elliott directly at: tei@ix.netcom.com

photo credit: CBP Photography Air and Marine Operations (AMO), recovery relief efforts in Raleigh North Carolina via photopin (license)

Tags: Environmental, Environmental risks, OSHA, EPA