A Plan of Action

Employers must suitably plan for emergencies that have the potential to cause serious multiple injuries or fatalities or have a wider impact.

The actions taken in the initial minutes during an emergency are critical.

The emergency procedure is a plan of actions to be conducted in an organised and planned order to provide a suitable response to an emergency event.

Complete an emergency plan if a major incident at your workplace could involve risks to the public, rescuing employees or coordinating emergency services.

Where you share your workplace with another employer, consider whether your emergency plans and procedures need coordinating.

Examples of potential incidents where an emergency plan would be required are:

• Fire
• Explosion
• Electrical incident
• Bomb threat or suspicious package
• Civil disorder or violence
• Flooding or extreme weather
• Gas leaks
• Chemical spillage or release
• Radiological incident or release
• Lift entrapment
• Trapped persons in an excavation or confined space

Your risk assessment process should be the tool to guide you as to the hazards of the workplace and the severity and likelihood of harm occurring.

Suitable measures and controls to reduce the severity of consequences involve measures to ensure people know exactly how to respond and act in an emergency situation when time is of the essence.

“emergency practices or drills should be suitably planned, rehearsed, and recorded”

For this an organisation must ensure that their employees and other persons on the premises, as well as key role holders are competent, well trained and practiced in the emergency measures.

With regard to practice of emergency measures, the practices or drills should be suitably planned, rehearsed, and recorded, so that actions are practiced, failures in the emergency procedure can be identified and very importantly that come a real emergency, key responders and all personnel carry out their roles in a more automated way when under real pressure because the steps they are taking are already familiar to them.

If there is the potential for a major incident at your workplace could that involve the public, or coordinating with the emergency services, then this should be factored in your emergency plan.

If your premises are shared by other companies or organisation, then your suitable emergency plan should also be coordinated and communicated with these organisations.

What should emergency procedures include?

• Information on all the foreseeable emergencies.
• Procedures for raising the alarm in the event of an emergency. (This should also consider night shifts, holidays and the 24-hour cycle of the organisation and its premises.)
• Detail step by step the procedures that require to be followed.
• Provide and suitably maintain and inspect suitable equipment that would be required in an emergency.
• Nomination of responsible competent Incident Controllers for actioning the emergency plan.
• Ensure that the Incident Controllers have relevant technical competence for the foreseeable emergencies (e.g. a Radiation Protection Advisor for a radiological emergency, confined space trained staff if the emergency involves rescue from a confined space, etc.)
• Ensure that there is clear and available inventory of hazardous substances available to be given to emergency services if required.
• Provision of information, instruction and training to all staff and emergency role holders.
• Carry out regular drills and exercises to test how effective the emergency procedures are.
• Detail arrangements for contacting the emergency services (Who? When? And how?)
• Have a clear drawing or plan showing where hazardous items are located on the site.
• Ensure that there is a clearly signed and safe assembly point for persons to evacuate to in the event of an emergency.
• Provide suitably signed exit routes, exit routeways clear from obstruction, and have suitable emergency lighting.
• Have suitable first aid provision in terms of first aid equipment and qualified first aiders.
• Plan essential safety actions such as shutdown of plant, isolations, shutting off valves or isolators.
• Arrangements for confirming when the emergency is declared over or a false alarm and the conditions by which the premises can be re-populated and used.

“ensure that there is clear and available inventory of hazardous substances available to be given to emergency services”

First-aid considerations

In accordance with the Health and Safety (First Aid) Regulations 1981, an employer as a duty to make appropriate first-aid provision for their employees.

These measures are to provide an emergency response immediately as a first responder and should be based on the first aid risk assessment.

A suitable first aid provision consists of:

• Having suitable equipment including well stocked first aid kits and other suitable equipment including eye wash facilities or a defibrillator.
• Having a suitable location to give first-aid treatment.
• Having suitably trained first aiders, with a suitable number of trained first aiders based on the first aid risk assessment considering the risks for the premises and the number of people on the premises. The HSE has guidance for planning for types of trained first aiders, including Emergency First Aid at Work (EFAW 1 day course) qualified first aiders and First Aid at Work (FAW 3-day course) qualified first aiders. St Johns Ambulance also has an excellent and thorough first aider provision calculator tool to assist with determining your first aid provision requirements. You can find it here: https://www.sja.org.uk/course-information/guidance-and-help/working-out-what-you-need/first-aid-requirements-page/.

The contents requirements of a first-aid kit are detailed in the ACoP and guidance to the Health and Safety (First Aid) Regulations 1981.

The role of a first aider is to provide an immediate response to preserve life until professional medical assistance can take over.

First aid also covers the treatment to minor injuries also, that do not require further emergency responder treatment.

Provision of defibrillators

Provision of defibrillators considerably improve the chances of survival from a cardiac arrest. If your first aid risk assessment does not determine that a defibrillator is required to be bought for your premises due to the level of risk, it is still strongly advisable to identify where the nearest one is to your workplace. The ‘Heartsafe’ website (https://www.heartsafe.org.uk/aed-locations) provides a great resource helping you identify where are nearest defibrillators are to your premises.

Initial incident and emergency response

An organisation needs to consider and plan what equipment may be required as part of a response to an emergency, and the procedure that equipment. This may include for example lifting equipment required for a rescue from height or in an excavation, or an evacuation chair.

The organisation should clearly plan:

• What equipment is required.
• How many of the items are needed?
• Where will the equipment be located?
• What training provision is required in its use.
• How often will the equipment require inspection to ensure suitably maintained and tested.
• What statutory requirements need to be carried out to comply with the law, specifically ‘The Provision and Use of Work Equipment Regulations 1998’ (PUWER) and ‘The Lifting Operations and Lifting Equipment Regulations 1998’ (LOLER), such as ensuring that lifting equipment has an in-date examination test certificate.

“an organisation needs to plan what equipment may be required as part of a response to an emergency”

The legal requirements

The main legal requirements for having suitable emergency procedures come from:

• The Health and Safety at Work etc. Act 1974 – this places a duty on employers and persons with control over premises to put in place measures ensure the health, safety and wellbeing of employees and persons on the premises so far as is reasonably practicable, and to provide and maintain means of access and egress that are safe.
• The Management of Health and Safety at Work Regulations 1999 – requires employers to carry out a suitable and sufficient risk assessment, and Regulation eight requires employers to have ‘Procedures for serious and imminent danger and for danger areas’.
• The Dangerous Substances (Notification and Marking of Sites) Regulations 1990 – these Regulations cover sites where at least 25 tonnes of dangerous substances are held. – If you have 25 tonnes or more of dangerous substances, you must notify the fire and rescue service and put-up suitable warning signs.
• The Regulatory Reform (Fire Safety) Order 2005 – detail the requirements for Fire Safety and having suitable fire evacuation measures.

• The Dangerous Substances and Explosive Atmospheres Regulations 2002.
• The Radiation (Emergency Preparedness and Public Information) Regulations 2019.
• Specific sets of Health and Safety legislation that are applicable to the specific hazards in your workplace, such as COSHH, Confined Spaces, Electricity at Work, Work at Height.
• Legislation applicable to equipment that you plan to use in an emergency such as LOLER or PUWER.

Vulnerable persons/disabilities

An organisation should consider and risk assess whether they have suitable emergency procedures for any vulnerable persons and people with disabilities on their premises or in their employ.

They may consider that a Personal Emergency Evacuation Plan (PEEP) would be suitable.

A PEEP should be developed jointly between the person and their line manager to enable there to be a clear plan for the person to exit the premises during an emergency. 

If the individual were to have difficulty in hearing the alarm or evacuating a building unaided in the event of an emergency, then a PEEP is likely to be required. The assistance of others may be required, and detailed within the PEEP.

“an organisation should risk assess whether they have suitable emergency procedures for people with disabilities”

Public events and visitors

Based on the risk assessment for a public event or the public on your premises, an organisation should develop their emergency procedures to be followed by staff and volunteers, and the public in a significant incident/emergency.

Measures should also be put in place to ensure that the public are suitably informed and instructed on the actions in the event of an emergency.

The emergency plan should also cover contingencies and arrangements for major incidents that will require coordination with the emergency services.

Terrorism threats

There is specific advice to help mitigate the threat of a terrorist attack in crowded places provided by the National Counter-terrorism Security Office.

Sharing plans with authorities

With the exception of the smallest low risk events or fixed venues with established procedures, it is advised that your emergency plan be discussed with the emergency services, including the police, fire and rescue service and the ambulance service.

Emergency procedures for staff and volunteers for an event involving the public should specifically consider:

• How to raise the alarm
• To inform the public of actions
• Onsite emergency response
• Calling the emergency services and ongoing liaison with them
• Crowd management, and their ‘safe evacuation’
• Evacuation of vulnerable persons and people with disabilities
• Traffic management, including emergency vehicles and their access
• Incident control
• Provision of first aid and medical assistance

For emergency exits and escape routes, signage, and lighting:

• Plans should be in place to ensure that escape routes are and remain unobstructed throughout an event. All exits must remain unlocked, be free from obstructions and open in the direction of travel.
• Exit routes should be clearly signed factoring in that members of the public would not have had an emergency drill like an employee would have.
• Exit routes should also be suitably lit, and with Emergency lighting that complies with British Standard BS 5266-1. Use an independent power source if there were to be a power cut.

For vulnerable persons:

• The emergency evacuation plan should also the additional assistance and requirements for vulnerable people including persons with disabilities, elderly, and children.

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• www.hse.gov.uk. (n.d.). Emergency procedures. [online] Available at: https://www.hse.gov.uk/toolbox/managing/emergency.htm.
• Health and Safety Executive (2015). Event safety – Planning for incidents and emergencies. [online] Hse.gov.uk. Available at: https://www.hse.gov.uk/event-safety/incidents-and-emergencies.htm.
• Allianz UK. (n.d.). Emergency procedures. [online] Available at: https://www.allianz.co.uk/risk-management/risk-topics/health-safety/emergency-procedures.html [Accessed 18 Apr. 2022].
• www.london-fire.gov.uk. (n.d.). Your Emergency Plan – Fire safety at work. [online] Available at: https://www.london-fire.gov.uk/safety/the-workplace/your-emergency-plan/.
• www.heartsafe.org.uk. (n.d.). AED Defibrillator UK Locations / Find an AED / Defibrillator. [online] Available at: https://www.heartsafe.org.uk/aed-locations.
• www.sja.org.uk. (n.d.). First Aid Requirements Page / St John Ambulance. [online] Available at: https://www.sja.org.uk/course-information/guidance-and-help/working-out-what-you-need/first-aid-requirements-page/ [Accessed 18 Apr. 2022].
• Legislation.gov.uk. The Health and Safety at Work etc. Act 1974. [online] Available at: https://www.legislation.gov.uk/
• Legislation.gov.uk. The Management of Health and Safety at Work Regulations 1999. [online] Available at: https://www.legislation.gov.uk/
• Legislation.gov.uk. The Dangerous Substances (Notification and Marking of Sites) Regulations 1990. [online] Available at: https://www.legislation.gov.uk/
• Legislation.gov.uk. The Regulatory Reform (Fire Safety) Order 2005 [online] Available at: https://www.legislation.gov.uk/
• Legislation.gov.uk. The Dangerous Substances and Explosive Atmospheres Regulations 2002 [online] Available at: https://www.legislation.gov.uk/
• Legislation.gov.uk. The Radiation (Emergency Preparedness and Public Information) Regulations 2019 [online] Available at: https://www.legislation.gov.uk/