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Does my propane company need an Emergency Action Plan?

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By Bill Stomp, Founder/Editor · Last updated November 4, 2026

Question: “Does my propane company need an Emergency Action Plan?”

Only when another OSHA rule calls for one. 29 CFR 1910.38 sets what the plan must look like. It does not by itself say who needs one. One common case: if you keep fire extinguishers but your crew is told to leave instead of using them, OSHA's fire extinguisher rule, 29 CFR 1910.157, expects an Emergency Action Plan and a fire prevention plan.

Does it have to be written?

If you have more than 10 employees, yes. With 10 or fewer, the rule lets you share the plan out loud, but a written copy still makes training easier.

What goes in it?

The rule lists reporting an emergency, evacuation steps and exit routes, what employees who stay behind do, how you account for everyone, rescue and medical duties, and who to contact for more information. Read paragraph (c) of the rule against your own plan.

Who tells the crew?

Review the plan with each covered employee when the plan is developed or the employee is initially assigned to a job, when the employee's responsibilities under the plan change, and when the plan changes.

We help with safety manual writing, review and revision; see propane safety help.

Frequently asked questions

Who needs an Emergency Action Plan?

Employers covered by another OSHA rule that calls for one, such as the fire extinguisher rule (29 CFR 1910.157) when employees are told to leave instead of using extinguishers.

When must it be written?

When you have more than 10 employees.

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