In June, the US Occupational Safety and Health Administration (OSHA) and other federal agencies reacted to flooding in Florida by re-highlighting existing guidance to support preparation for potential flooding this summer, and to respond when it occurs. OSHA’s guidance is directed at employers, while the National Weather Service (NWS) provides 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 flooding?
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 Flood Preparedness and Response webpage reminds employers that their General Duty covers flood preparation and response in appropriate workplaces.
How should employers prepare for onsite response to flooding?
Depending on the workplace, flooding may introduce a variety of new or exacerbated hazards, which employers should prepare to address. 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 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 prepare for flooding-induced evacuations?
Employers should also plan for the possibility that some or all of employees in a workplace may respond to flooding with an evacuation. OSHA references its Emergency Action Plan standard (see above), and notes that a “thorough” evacuation plan should include the following:
- 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
What happens next?
Flooding events have become more frequent in recent years, as part of more severe weather conditions accompanying climate change. Recent information outreach by federal agencies is a good reminder that employers with workplaces exposed to flooding hazards should have established and reviewed flood response plans appropriate to their employee-protection policies.
Self-evaluation checklist
Has the organization reviewed the range of hazards associated with weather- or other disaster-related floods?
Has the organization evaluated its facilities and operations to identify which may be subject to flooding 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 flooding, and if so, has the organization reviewed the event(s) to inform its risk evaluation and response planning activities?
Where can I go for more information?
- OSHA
- National Weather Service “Flood Safety Tips and Resources” webpage
- Centers for Disease Control and Prevention (CDC) “Floods and Your Safety” webpage
- Environmental Protection Agency (EPA), Flooding Response 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