15.1 Emergency Action Plans, Medical Services, First Aid & Sanitation (1926.35 / .50 / .51)
Key Takeaways
- Under 29 CFR 1926.35(e)(3), the emergency action plan must be written and kept at the workplace, except that employers with 10 or fewer employees may communicate the plan orally.
- 29 CFR 1926.50(c) requires a person holding a valid first-aid certificate to be available at the worksite whenever no infirmary, clinic, hospital, or physician is reasonably accessible in terms of time and distance.
- First aid supplies must be in a weatherproof container with individual sealed packages for each item, checked by the employer before being sent out on each job and at least weekly on each job (29 CFR 1926.50(d)(2)).
- Where eyes or body may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing must be provided within the work area for immediate emergency use (29 CFR 1926.50(g)).
- The toilet ratio in 29 CFR 1926.51(c)(1) is one facility for 20 or fewer employees, then one toilet seat and one urinal per 40 workers, and one toilet seat and one urinal per 50 workers at 200 or more.
15.1 Emergency Action Plans, Medical Services, First Aid & Sanitation
The 30-hour Construction Outreach curriculum reserves 4 optional hours for "other construction industry hazards or policies," and emergency preparedness plus site welfare is one of the most common uses of that time. These provisions are also cited constantly, because compliance is visible from the gate: is there a plan, is there a trained first-aider, is there potable water, are there enough toilets.
1. Emergency Action Plans — 29 CFR 1926.35
The six required elements — 1926.35(b)
At a minimum, the plan must include:
- Emergency escape procedures and emergency escape route assignments
- Procedures to be followed by employees who remain to operate critical plant operations before they evacuate
- Procedures to account for all employees after emergency evacuation has been completed
- Rescue and medical duties for those employees who are to perform them
- The preferred means of reporting fires and other emergencies
- Names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan
[!NOTE] Element 3 is the one that fails in the field. Head counts at the muster point are the only mechanism that tells an incident commander whether anyone is still in the building. On a site with a dozen subcontractors and a floating workforce, this requires a defined muster location per phase, a defined accounting method, and a defined person responsible.
Alarm system — 1926.35(c)
The employer must establish an employee alarm system complying with 1926.159. If the alarm is used for alerting fire brigade members or for other purposes, a distinctive signal for each purpose must be used. Under 1926.159, the alarm must be capable of being perceived above ambient noise or light levels by all employees in the affected portions of the workplace.
Evacuation types and exit route assignments — 1926.35(d)
The employer must establish in the plan the types of evacuation to be used in emergency circumstances — full evacuation, partial evacuation, or shelter in place.
Training — 1926.35(e)
| Requirement | Provision |
|---|---|
| The employer must designate and train a sufficient number of persons to assist in the safe and orderly emergency evacuation of employees | 1926.35(e)(1) |
| The employer must review the plan with each covered employee: initially when the plan is developed, whenever the employee's responsibilities or designated actions change, and whenever the plan is changed | 1926.35(e)(2) |
| The written plan must be kept at the workplace and made available for employee review. Employers with 10 or fewer employees may communicate the plan orally and need not maintain a written plan | 1926.35(e)(3) |
[!CAUTION] The 10-employee threshold works in a specific direction. With more than 10 employees, the plan must be written and kept at the workplace. With 10 or fewer, it may be communicated orally. The obligation to have a plan does not disappear at 10 employees — only the writing requirement does.
Construction-specific emergency scenarios worth planning
| Scenario | Plan elements |
|---|---|
| Trench collapse | Non-entry rescue only; call 911 immediately; never send workers in (Chapter 5) |
| Confined space emergency | Pre-arranged rescue service evaluated in advance; non-entry retrieval; attendant never enters (Section 7.5) |
| Fall arrest / suspension trauma | Post-fall rescue plan with a defined method and time target; suspension intolerance can develop rapidly (Chapter 2) |
| Crane contact with power lines | Operator stays in the cab unless fire forces evacuation; then jump clear, feet together, shuffle away (Section 3.3) |
| Severe weather / high wind | Wind-speed thresholds for crane, scaffold, masonry, and tilt-up operations; defined shelter locations; lightning evacuation |
| Structural collapse | Immediate exclusion zone; no re-entry without engineering assessment |
2. Medical Services and First Aid — 29 CFR 1926.50
| Provision | Requirement |
|---|---|
| (a) | The employer must ensure the availability of medical personnel for advice and consultation on matters of occupational health |
| (b) | Provisions must be made prior to commencement of the project for prompt medical attention in case of serious injury |
| (c) | In the absence of an infirmary, clinic, hospital, or physician that is reasonably accessible in terms of time and distance to the worksite, a person who has a valid certificate in first-aid training from the U.S. Bureau of Mines, the American Red Cross, or equivalent training verifiable by documentary evidence, must be available at the worksite to render first aid |
| (d)(1) | First aid supplies must be easily accessible when required |
| (d)(2) | Contents of the first aid kit must be placed in a weatherproof container with individual sealed packages for each type of item, and must be checked by the employer before being sent out on each job and at least weekly on each job to replace expended items |
| (e) | Proper equipment for prompt transportation of the injured person to a physician or hospital, or a communication system for contacting necessary ambulance service, must be provided |
| (f) | In areas where 911 is not available, telephone numbers of physicians, hospitals, or ambulances must be conspicuously posted |
| (g) | Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body must be provided within the work area for immediate emergency use |
"Reasonably accessible in terms of time and distance"
The standard does not state a number, but OSHA has interpreted the requirement consistently in guidance and letters of interpretation:
- For injuries where life is threatened — cardiac arrest, airway obstruction, or severe bleeding — the response time should be 3 to 4 minutes, because irreversible brain damage from oxygen deprivation begins in roughly that window.
- For less serious injuries, a response time of no more than 15 minutes is generally acceptable.
[!CAUTION] Exam framing: a scenario placing a jobsite 25 or 30 minutes from the nearest emergency department is describing a site where medical care is not reasonably accessible, which triggers the 1926.50(c) requirement for a certified first-aider on site. Note that the standard says "first-aid training"; most employers meet it with combined first aid, CPR, and AED certification, and 1926.50 does not itself require CPR certification by name.
Eyewash — 1926.50(g)
The construction standard is performance-based: suitable facilities for quick drenching or flushing, within the work area, for immediate emergency use. Where the exposure is to a strong corrosive — masonry cleaning acid, concrete admixtures, battery electrolyte — the widely adopted consensus benchmark is ANSI/ISEA Z358.1, which specifies a 10-second travel time (roughly 55 feet on an unobstructed path) and a 15-minute flush duration. A personal squeeze bottle is a supplement to a plumbed or gravity-fed unit, never a substitute for one.
3. Sanitation — 29 CFR 1926.51
Sanitation is not a comfort provision. Dehydration is a direct contributor to heat illness (Section 9.5), and inadequate handwashing drives lead and silica take-home exposure to workers' families (Section 9.3).
Potable water — 1926.51(a)
| Requirement | Provision |
|---|---|
| An adequate supply of potable water must be provided in all places of employment | 1926.51(a)(1) |
| Portable containers must be capable of being tightly closed and equipped with a tap; water must not be dipped from the container | 1926.51(a)(2) |
| Any container used to distribute drinking water must be clearly marked as to its contents and must not be used for any other purpose | 1926.51(a)(3) |
| The common drinking cup is prohibited | 1926.51(a)(4) |
| Where single-service cups are supplied, both a sanitary container for unused cups and a receptacle for used cups must be provided | 1926.51(a)(5) |
1926.51(b): outlets for nonpotable water — such as water for industrial or firefighting purposes — must be identified by signs meeting 1926.200 to indicate clearly that the water is unsafe and is not to be used for drinking, washing, or cooking. There must be no cross-connection, open or potential, between a potable and a nonpotable system.
Toilets — 1926.51(c)
| Number of Employees | Minimum Number of Facilities |
|---|---|
| 20 or fewer | 1 |
| 20 or more | 1 toilet seat and 1 urinal per 40 workers |
| 200 or more | 1 toilet seat and 1 urinal per 50 workers |
1926.51(c)(2): Under temporary field conditions, provision must be made to assure not less than one toilet facility is available.
1926.51(c)(3): This section does not apply to mobile crews having transportation readily available to nearby toilet facilities.
1926.51(c)(4): Job sites not provided with a sanitary sewer must be provided with chemical toilets, recirculating toilets, combustion toilets, or flush toilets.
Washing facilities — 1926.51(f)
The employer must provide adequate washing facilities for employees engaged in the application of paints, coatings, herbicides, or insecticides, or in other operations where contaminants may be harmful. The facilities must be in near proximity to the worksite and must be so equipped as to enable employees to remove such substances.
[!NOTE] Washing facilities are a lead and silica control. 1926.62(i) requires clean change areas, showers where feasible, and handwashing facilities for lead work; 1926.1153(i) drives the same logic for silica. A worker who eats lunch with lead dust on their hands ingests lead, and a worker who drives home in contaminated clothes brings it to their family.
Eating and drinking areas — 1926.51(g) and food handling — 1926.51(d)
No employee shall be allowed to consume food or beverages in a toilet room or in any area exposed to a toxic material. All food service facilities and operations must meet applicable state and local laws, and all employee food service facilities must be sanitary.
4. Signs, Signals, and Barricades — 29 CFR 1926 Subpart G
Subpart G supports every emergency and welfare provision above by making hazards and instructions visible.
| Sign Type | Colors | Use | Citation |
|---|---|---|---|
| Danger | Red, black, and white | Immediate hazard; special precautions necessary | 1926.200(b) |
| Caution | Yellow background, black panel with yellow letters | Warn against potential hazards or caution against unsafe practices | 1926.200(c) |
| Exit | Legible, per the standard | Marking exits | 1926.200(d) |
| Safety instruction | White background, green panel with white letters | General instructions relating to safety measures | 1926.200(e) |
| Directional | White with black panel and white directional symbol | Directions to first aid, medical, and similar facilities | 1926.200(f) |
| Traffic | Per MUTCD | Construction areas where traffic hazards exist | 1926.200(g) |
| Accident prevention tags | Per 1926.200(h) | Temporary hazards — "Do Not Start," "Do Not Operate," "Out of Order," defective equipment | 1926.200(h) |
Flaggers (1926.201(a)) must use STOP/SLOW paddles, hand-signaling devices, or red flags conforming to the MUTCD, and must wear high-visibility apparel as covered in Section 11.3.
A general contractor with 42 employees on a rural bridge project maintains an emergency action plan that the superintendent briefs verbally at orientation. The nearest hospital is 28 minutes away by road. Which two deficiencies exist?
A jobsite has 180 workers and no connection to a sanitary sewer. Under 29 CFR 1926.51(c), what sanitation provision is required?
A restoration crew will apply a strong acidic masonry cleaner from a swing stage. Which requirement of 29 CFR 1926.50 applies specifically to this exposure?