In October, the US Occupational Safety and Health Administration (OSHA) and other federal agencies reacted to hurricanes in the Southeast by re-highlighting existing guidance to support preparation for potential hurricanes, and to respond if one occurs. OSHA’s guidance is directed at employers, the National Oceanic and Atmospheric Administration (NOAA) and the Environmental Protection Agency (EPA) provide more generalized guidance, and the Centers for Disease Control and Prevention (CDC) target families. The rest of this note summarizes this timely information, centering on OSHA’s offerings.
What are employers’ responsibilities to prepare for hurricane preparedness and response?
The federal Occupational Safety and Health Act requires employers to evaluate workplace hazards and protect workers from “recognized hazards”, including those specifically targeted by OSHA’s regulatory standards as well as a “General Duty’ to address hazards that are not (yet) covered by OSHA (I’ve written about this several times, most recently HERE). OSHA’s Hurricane Preparedness and Response webpage reminds employers that their General Duty covers flood preparation and response in appropriate workplaces.
What types of hazards do hurricanes present?
Hurricanes present hazards from sustained winds (at least 74 miles per hour (mph) to qualify as Category 1), as well as water-related hazards and disruptions to utilities and transportation. NOAA emphasizes the following hazards:
- Winds, including sustained winds from the hurricane itself and as well as associated tornadoes
- Storm surge from the ocean, including up estuaries and rivers
- Flooding
- Electricity and natural gas outages
- Structural damage and injuries from collapsing and flying materials
How should employers prepare for hurricanes?
Employers need to review their workplace’s susceptibility to wind and flood, and the degree to which onsite and offsite infrastructure and structures can withstand damage. Because hurricanes can cause localized and even regional devastation, employers must prepare for the possibility their workplaces will be isolated from normal outside assistance for extended periods.
OSHA provides additional guidance for these hazards. For example, OSHA identifies common flooding hazards to include:
- Electrical hazards
- Tree and debris removal
- Carbon monoxide
- Lifting injuries
- Mold
- Rodents, snakes and insects
- Chemical and biological hazards
- Fire
- Drowning
- Hypothermia (due to the cold weather and water exposure)
- Exhaustion (from working extended shifts)
- Heat
Training, equipment, and other preparation might be assembled under broader employer emergency response efforts, including:
- Emergency Action Plan (I wrote about these HERE)
- Emergency Response Plan under Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard (I wrote about these HERE)
- Onsite fire brigade (I wrote about OSHA’s proposal to supersede many of these requirements with a new Emergency Response Standard, HERE)
How should employers respond to hurricanes?
Hurricane response can include anticipatory actions such as evacuations or shelter-in-place activities, as well as post-event response and cleanups.
- How should employers prepare for hurricane-induced evacuations?
Employers should also plan for the possibility that some or all of employees in a workplace may respond before or after a hurricane with an evacuation. OSHA’s Emergency Action Plan standard (see above) includes 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
- Review the plan with workers
- How should employers conduct workplace cleanup and restoration?
OSHA does not provide specific guidance for onsite post-hurricane response, but employers should assess their situation and then develop and implement response activities. OSHA’s general guidance for incident response identifies the following general elements:
- Evaluate each hazard by considering the severity of potential outcomes, the likelihood that an event or exposure will occur, and the number of workers who might be exposed.
- Use interim control measures to protect workers until more permanent solutions can be implemented.
- Prioritize the hazards so that those presenting the greatest risk are addressed first. Note, however, that employers have an ongoing obligation to control all serious recognized hazards and to protect workers.
What happens next?
Hurricanes have become more frequent and more severe in recent years, as part of changing weather conditions accompanying climate change. Recent information outreach by federal agencies is a good reminder that employers with workplaces exposed to these hazards should have establish and review hurricane preparation and response plans appropriate to their employee-protection policies.
Self-evaluation checklist
Does the organization conduct any of its activities in locations subject to hurricanes?
Has the organization reviewed the range of hazards associated with hurricanes?
Has the organization evaluated its facilities and operations to identify which may be subject to hurricanes and hurricane-related hazards?
- If so, has the organization established emergency response plans identifying these hazards, and providing for equipment and training to implement them effectively?
Have any of the organization’s facilities or activities been subject to hurricanes, and if so, has the organization reviewed the event(s) to inform its ongoing risk evaluation and response planning activities?
Where can I go for more information?
- NOAA “Hurricane Preparedness” webpage
- Centers for Disease Control and Prevention (CDC) “Preparing for Hurricanes or Other Tropical Storms” webpage
- Environmental Protection Agency (EPA), “Hurricanes” webpage
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years.
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