Every employer must account for their personnel in an emergency.
As specified by OSHA regulations and NFPA standards, every employer shall account for every employee during any emergency. Not two hours or two days later.
The 911 Headcount System is the only Mass Emergency Notification System that allows for two-way contact. You can tell your people there’s an emergency, and they can tell you whether or not they’re still in danger. Why is it critical to have a two-way system in place?
It’s not just your employees you must account for.
Via premises liability, court and agency decisions, every employer must account for: employees, contractors, interns, volunteers, and site visitors. Do you currently have the capability to account for visitors and interns in an emergency?
As an employer, during any emergency, you have to be able to answer several questions from the police and fire chiefs:
“Can you account for everyone? Is anyone hurt? In anyone still in harm’s way?”
You must be able to answer these questions. What happens when you can’t answer them?
“4 Firefighters Killed After Hotel Collapse”
In Houston, TX, 2013, a 5-alarm fire broke out in a hotel. Over 150 firefighters responded – and 4 didn’t make it home. What went wrong?
Every occupant of the building evacuated within moments of the alarm going off. However, due to the property owner’s inability to perform an accurate headcount, the Houston Fire Department sent several firefighters into the blaze in search of remaining guests. They found nothing except a fire so strong it compromised the hotel’s structural integrity.
“We thought we had some civilians in the structure… Unfortunately, the building had much more fire in it than we originally thought. The structure collapsed… and our members who were trying to save lives were trapped.” – Fire Chief Terry Garrison
OSHA and the NFPA aren’t the only reasons to have a headcount system in place: without one, emergency responders will have to put themselves in harms way to save your people – even though they may no longer be in the building.
What are the relevant documents?
Every employer is covered. See sections 1910.34 through 1910.39, which apply to workplaces in general industry except mobile workplaces such as vehicles or vessels.
The relevant sections include:
Section (a) (Application): “An employer must have an emergency action plan.”
Section (c) (Minimum elements of an emergency action plan): “An emergency action plan must include at a minimum… Procedures to account for all employees after evacuation”
What does this mean? You must have an emergency action plan, and you must be able to account for your employees after an evacuation. Not 2 hours after an evacuation, but starting the moment the evacuation is initiated. What can happen when you can’t account for your people after initiating an evacuation?
No employer – non-profit, church, school, office, etc – is exempt.
National Standards demand employers to be able to notify all personnel during emergencies:
NFPA 1600 (2013 Edition)
6.5 Warning, Notifications, and Communications.
6.5.2* Warning, notification, and communications systems shall be reliable, redundant, and interoperable.
6.5.3* Emergency warning, notification, and communications protocols and procedures shall be developed, tested, and used to alert stakeholders potentially at risk from an actual or impending incident.
NFPA 72 (2013 Edition)
24.3.3* Required Emergency Communications Systems. An emergency communications system shall be installed in occupancies where required by the authority having jurisdiction or by other applicable governing laws, codes, or standards.
NFPA 72 Chapter 24 Emergency Communications Systems goes on for 74 pages describing the details of such systems in workplaces.
Additionally, there are state and local regulations that can apply to you. For example, every tenant employer, in every one of New York City’s 1,800 high rises shall:
3RCNY §6-02(o)(2)(iv)
“establish and maintain a system…so that an accounting can be made in the event of an in-building relocation, partial evacuation or evacuation.”
What does this mean for you?
For decades, federal law has required that all employers account for personnel during any emergency. National standards describe the design and application of such systems, but these standards are highly complex. Do not assume you can implement these systems without outside help: it puts lives at risk, and if someone is injured it opens your organization to civil and criminal suits, as well as hefty fines.
If you don’t have a headcount system in place yet, call us. We will help you ensure your people are protected and your organization is prepared to survive a disaster.