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Pan ERP

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A pan fire or pan-related incident ERP should clearly define whether employees will evacuate only or whether designated, trained responders will take limited defensive actions or full emergency response actions. Under OSHA, employers that evacuate employees from the danger area and do not permit them to assist in handling the emergency may rely on an emergency action plan under 29 CFR 1910\.38; if employees take response actions beyond evacuation, the plan must address emergency response requirements under 29 CFR 1910\.120(q). For PSM-covered operations, the employer must establish and implement an emergency action plan for the entire plant and include procedures for handling small releases. [8] [7]

For a practical pan fire ERP, include the following elements:

  • Hazard assessment for the pan operation: identify fuel sources, combustible/flammable liquids, hot oil or grease, nearby combustibles, ignition sources, ventilation effects, splash/boilover potential, toxic smoke, and whether the incident could escalate into a hazardous substance release or process upset.
  • Alarm and notification procedures: define how to report the fire, activate internal alarms, notify supervision, summon the fire department, and notify outside emergency response parties and mutual-aid partners.
  • Roles and command structure: establish an incident command system (ICS), identify the incident commander, and assign shutdown, evacuation, accountability, fire brigade, medical, and liaison responsibilities.
  • Evacuation and accountability: specify alarm tones, exit routes, assembly points, headcount procedures, criteria for shelter-in-place versus evacuation, and methods to keep personnel out of hazard zones.
  • Emergency shutdown and isolation: identify who may shut off burners, electricity, fuel, ventilation, pumps, or feed systems; what valves or disconnects may be operated; and when shutdown must stop because conditions are unsafe.
  • Fire response procedures: state when a small incipient-stage pan fire may be attacked with the correct extinguisher or fixed suppression system, and when employees must back out and wait for the fire department.
  • PPE requirements: specify task-based PPE for evacuation wardens, incipient-stage extinguisher users, fire brigade members, and hazmat responders, including limitations, inspection, maintenance, and decontamination where contamination is possible.
  • Medical and rescue interface: define first-aid, burn treatment, EMS activation, and rescue limitations so untrained employees do not attempt hazardous rescue.
  • Post-incident actions: secure the area, preserve evidence as appropriate, investigate root causes, document corrective actions, review findings with affected personnel, and retain required records.
  • Training, drills, and plan review: train employees on alarms, evacuation, extinguisher use if authorized, shutdown steps, PPE, and ICS roles; conduct drills if required by the employer's own plans; and periodically audit and update the ERP.

[6] [5] [7] For hazard assessment, evaluate the pan process before an incident occurs and again dynamically during the event. Key factors include what is burning, whether water contact could worsen the fire, whether the pan is part of a larger process, whether there are pressurized or energized systems nearby, whether smoke or vapors create inhalation hazards, and whether responders would need to enter a contamination or high-heat zone. If the pan incident involves hazardous substances or process chemicals, the ERP should align with local or state emergency response plans and outside responders must understand their roles and any limitations that could delay response. [4] [6] [2]

For fire safety procedures, the ERP should require immediate alarm activation, rapid size-up, and strict control of extinguishment methods. For pan fires involving cooking oils, flammable liquids, or reactive materials, employees should never apply an extinguishing agent that can spread burning liquid or cause violent splatter. The plan should identify the correct extinguishing media and fixed systems for the specific pan hazard, require responders to approach from a safe position with a clear exit path, and mandate withdrawal if the fire is beyond incipient stage, threatens adjacent equipment, or produces untenable heat or smoke. Emergency equipment inventories must be known so responders can use PPE and response equipment effectively. [1] [3]

For evacuation, the ERP should establish immediate evacuation triggers such as loss of control of the pan fire, activation of suppression systems, smoke migration into occupied areas, suspected hazardous atmosphere, or inability to safely isolate energy sources. Evacuation routes must avoid the fire area and any smoke or contamination zones, and the plan should include accountability at assembly points. If the employer's strategy is evacuation-only, employees must not re-enter or attempt emergency control actions beyond those specifically allowed in the plan. [8] [9]

For emergency shutdown, the ERP should identify pre-authorized shutdown steps for the pan system and adjacent hazards, including fuel isolation, electrical disconnects, process feed cutoffs, ventilation controls, and lockout points where applicable. If operators are expected to take limited actions such as closing valves or isolating equipment from outside the immediate hazard area, those actions must be specifically addressed in the ERP and matched to the employees' training level. Shutdown procedures should be simple, posted, and drilled so employees do not improvise during an emergency. [9] [9]

For incident response organization, use an ICS with one incident commander controlling tactical decisions, communications, and scene safety. The ERP should define when command transfers to the fire department or unified command, how the safety officer function is assigned, and how contractors or skilled support personnel are briefed before entering any exposure area. Outside agencies should be integrated into the ERP through local/state plans or written agreements so responsibilities are clear before an event occurs. [5] [4] [1]

For PPE, the ERP should specify PPE by task and hazard level rather than using one default ensemble. At minimum, identify protection for heat/flame exposure, eye/face hazards, hand protection, foot protection, respiratory hazards, and contamination potential. A written PPE program should cover hazard identification, selection, use, maintenance, decontamination, training, and periodic evaluation. The plan must also address the limitations of PPE, since over-protection can create heat stress, impaired vision, mobility, and communication problems. Where respiratory protection is needed for smoke, toxic vapors, or oxygen-deficient atmospheres, only properly selected and trained responders should enter. [5] [5] [1]

For post-incident response, the ERP should require scene stabilization, medical evaluation of exposed employees, preservation of key evidence where feasible, formal incident investigation, root-cause analysis, corrective action tracking, communication of findings to affected personnel, and retention of investigation records. Near misses and small fires should also be reviewed because they may reveal conditions that could reasonably have resulted in a catastrophic event. [7] [7] [10]

For OSHA and regulatory compliance, the ERP should be written, site-specific, accessible, and coordinated with the facility emergency action plan, hazard communication program, lockout/tagout procedures, fire brigade procedures if applicable, and any PSM documentation. If the facility is covered by PSM, emergency planning and response under 1910\.119(n), incident investigation under 1910\.119(m), and compliance audits at least every three years under 1910\.119(o) are key requirements. If employees respond to hazardous substance emergencies, the employer must implement the applicable HAZWOPER emergency response provisions, including ICS, PPE, training, and coordination with outside responders. If the ERP or EAP includes drills, the employer must conduct them as written. [7] [7] [8]

In practice, the strongest pan fire ERP is one that limits employee actions to their actual training level, pre-plans shutdown and evacuation decisions, integrates outside responders, and treats every fire, near miss, or uncontrolled pan event as a trigger for corrective action and plan improvement.

10 source record(s)

Sources used for this answer

[1] Oregon OSHA Program Directive | Hazardous Waste Operations and Emergency Response: Responding to Hazardous Substance Releases

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# PROGRAM DIRECTIVE (cont.) ## Significant Changes. (cont.) Failure to properly train employees in the selection and proper use of PPE must be cited under 1910.120(q)(6). 13. (q)(2)(xii) Use of the Local Emergency Response Plan (LERP) or the State Emergency Response Plan (SERP). - Community emergency response agencies should be integral components of the community ERP. The community-wide ERP should spell out specific roles and responsibilities for various organizations or agencies, and will state which function each agency is expected to play in the event of an emergency. The employer's ERP may reference or otherwise include all or applicable sections of a LERP or SERP. D. Procedures for Handling Emergency Response – 1910.120(q)(3). - At ongoing or recently completed emergency response operations there is usually a shift in emphasis from the planning requirements of the standard toward the procedural requirements of the standard. An inspection of an actual emergency response should focus on the appropriate implementation of the ERP and compliance with the requirements of 1910.120(q)(3). - Upon arriving at an emergency response incident the CSHO should immediately seek out and report to the on-scene IC (or the on-scene coordinator (OSC) if the NCP is activated), or the appropriate official within the Incident Command System (ICS), such as the safety and health official (safety officer). The purpose of this meeting is to inform the IC/OSC of your presence and the purpose of the visit. (Note: OSHA Instruction HSO 01-00-001, National Emergency Management Plan (NEMP), clarifies procedures and policy for OSHA during response to nationally significant incidents. According to the NEMP, any decision to discontinue consultation and assistance in favor of enforcement at a nationally significant incident or other emergency, including at what point during an incident this transition should occur, if at all, will be made by the Regional Administrator in consultation…

[2] Occupational Safety and Health Standards (OSHA 29 CFR 1910) - 1910.119 App C - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory)

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) management of change provisions. In addition, the management of change procedures are used to insure that the equipment and procedures are returned to their original or designed conditions at the end of the temporary change. Proper documentation and review of these changes is invaluable in assuring that the safety and health considerations are being incorporated into the operating procedures and the process. - Employers may wish to develop a form or clearance sheet to facilitate the processing of changes through the management of change procedures. A typical change form may include a description and the purpose of the change, the technical basis for the change, safety and health considerations, documentation of changes for the operating procedures, maintenance procedures, inspection and testing, P&IDs, electrical classification, training and communications, pre-startup inspection, duration if a temporary change, approvals and authorization. Where the impact of the change is minor and well understood, a check list reviewed by an authorized person with proper communication to others who are affected may be sufficient. However, for a more complex or significant design change, a hazard evaluation procedure with approvals by operations, maintenance, and safety departments may be appropriate. Changes in documents such as P&IDs, raw materials, operating procedures, mechanical integrity programs, electrical classifications, etc., need to be noted so that these revisions can be made permanent when the drawings and procedure manuals are updated. Copies of process changes need to be kept in an accessible location to ensure that design changes are available to operating personnel as well as to PHA team members when a PHA is being done or one is being updated. 12. Investigation of Incidents. Incide…

[3] Safety and Health Regulations for Construction (OSHA 29 CFR 1926) - 1926.65 App C - Compliance Guidelines

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# Occupational Safety and Health Administration (cont.) Those skilled support personnel, such as employees who work for public works departments or equipment operators who operate bulldozers, sand trucks, backhoes, etc., who may be called to the incident scene to provide emergency support assistance, should have at least a safety and health briefing before entering the area of potential or actual exposure. These skilled support personnel, who have not been a part of the emergency response plan and do not meet the training requirements, should be made aware of the hazards they face and should be provided all necessary protective clothing and equipment required for their tasks. - There are two National Fire Protection Association standards, NFPA 472 "Standard for Professional Competence of Responders to Hazardous Material Incidents" and NFPA 471 "Recommended Practice for Responding to Hazardous Material Incidents", which are excellent resource documents to aid fire departments and other emergency response organizations in developing their training program materials. NFPA 472 provides guidance on the skills and knowledge needed for first responder awareness level, first responder operations level, hazmat technicians, and hazmat specialist. It also offers guidance for the officer corp who will be in charge of hazardous substance incidents. 3. "Decontamination." Decontamination procedures should be tailored to the specific hazards of the site, and may vary in complexity and number of steps, depending on the level of hazard and the employee's exposure to the hazard. Decontamination procedures and PPE decontamination methods will vary depending upon the specific substance, since one procedure or method may not work for all substances. Evaluation of decontamination methods and procedures should be performed, as necessary, to assure that employees are not exposed to hazards by re-using PPE. References in appendix D may be used for guidance in establishing an effective dec…

[4] Oregon OSHA Program Directive | Hazardous Waste Operations and Emergency Response: Responding to Hazardous Substance Releases

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# GUIDANCE FOR OAR [redacted phone].120 EMERGENCY RESPONSE COMPLIANCE INSPECTION (cont.) <table><tr><th>I. Does the employer make use of the local or State ERP in the company ERP? If so, does the local or State ERP adequately provide employee protection for this employer? NOTE: Emergency response organizations may use the local or State ERP as part of their ERP to avoid duplication. However, the plan must address all of the provisions listed in OAR 437-002- 1910.120(q)(2) and (q)(3).</th><th>1910.120(q)(2)(xii)</th><th></th></tr><tr><td>J. Does the ERP reflect pre-emergency planning and coordination with outside parties?</td><td>1910.120(q)(2)(i)</td><td></td></tr><tr><td>1. Does the plan describe procedures or existing agreements addressing how the outside parties are to be notified of a potential emergency situation and what role each should play in an incident?</td><td>1910.120(q)(2)(i)</td><td></td></tr><tr><td>2. If any response coordination procedures or agreements are included in the plan, are the local fire department and other selected outside emergency response parties aware of their roles and responsibilities as described in the plan?</td><td>1910.120(q)(2)(i)</td><td></td></tr><tr><td>3. Can outside responders identify any reasons that were not considered by the employer that would delay or prevent them from responding to an incident (e.g., distance, lack of training, etc.)?</td><td>1910.120(q)(2)(i)</td><td></td></tr></table> C-6

[5] Occupational Safety and Health Standards (OSHA 29 CFR 1910) - 1910.120 App C - Compliance Guidelines

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# Occupational Safety and Health Administration (cont.) ## Appendix C to § 1910.120 - Compliance Guidelines (cont.) Materials Emergency Planning Guide, NRT-1. The current Emergency Response Guidebook from the U.S. Department of Transportation, CMA's CHEMTREC and the Fire Service Emergency Management Handbook may also be used as resources. Employers involved with treatment, storage, and disposal facilities for hazardous waste, which have the required contingency plan called for by their permit, would not need to duplicate the same planning elements. Those items of the emergency response plan that are properly addressed in the contingency plan may be substituted into the emergency response plan required in 1910.120 or otherwise kept together for employer and employee use. 5. Personal protective equipment programs. The purpose of personal protective clothing and equipment (PPE) is to shield or isolate individuals from the chemical, physical, and biologic hazards that may be encountered at a hazardous substance site. - As discussed in appendix B, no single combination of protective equipment and clothing is capable of protecting against all hazards. Thus PPE should be used in conjunction with other protective methods and its effectiveness evaluated periodically. - The use of PPE can itself create significant worker hazards, such as heat stress, physical and psychological stress, and impaired vision, mobility, and communication. For any given situation, equipment and clothing should be selected that provide an adequate level of protection. However, over-protection, as well as under-protection, can be hazardous and should be avoided where possible. - Two basic objectives of any PPE program should be to protect the wearer from safety and health hazards, and to prevent injury to the wearer from incorrect use and/or malfunction of the PPE. To accomplish these goals, a comprehensive PPE program should include hazard identification, medical monitoring, environmental sur…

[6] MNOSHA Directive | 29 CFR 1910.119 and 29 CFR 1926.64, Process Safety Management of Highly Hazardous Chemicals - Compliance Guidelines and Enforcement Procedures

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# EXHIBIT 1: PRE-INSPECTION PREPARATION (cont.) ## INSPECTION STRATEGY (cont.) MNOSHA Instruction CPL 2-2.45B December 19, 2022 ## PLANNING AND SCHEDULING A. Create a Projected Timeline 1. Projected records and program review time 2. Projected walk around time 3. Projected write-up time B. Resource Scheduling 1. Team leader and construction specialist enter first for program and records review; present document request list. - 2 Full team enters following acquisition of requested documents for program/record review & walk around 3. Expert assistance enters as needed C. Equipment Acquisition 1. Required PPE 2. Technical equipment ## EXHIBIT 2: DOCUMENT REQUEST LIST ## I. PRE-UNIT-SELECTION A. OSHA 300 logs for past 3 years 1. Employer 2. Contractors B. Incident reports 1. Near miss 2. Fires 3. All releases (cross check with EPA documents) C. Site plan/Facility overview D. Simplified flow diagrams E. All permit procedures 1. Confined space 2. Hot work 3. Others F. Hazard communication G. Overall emergency response plan (emergency action plan, evacuation plan) H. Lockout/Tagout I. PPE plan/Requirements J. Audits 1. Internal 2. Corporate 3. Contracted 4. Insurance/Consultant K. Fire brigade records 1. Organizational statement 2. Training records Page 110 of 121

[7] Occupational Safety and Health Standards (OSHA 29 CFR 1910) - 1910.119 - Process safety management of highly hazardous chemicals

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# Employer responsibilities. (cont.) ## 1910.119(I)(4) (cont.) The factors that contributed to the incident; and, 1910.119(m)(4)(v) Any recommendations resulting from the investigation. 1910.119(m)(5) The employer shall establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented. - 1910.119(m)(6) The report shall be reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable. - 1910.119(m)(7) Incident investigation reports shall be retained for five years. - 1910.119(n) Emergency planning and response. The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall include procedures for handling small releases. Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q). ## 1910.119(0) Compliance Audits. 1910.119(o)(1). Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. 1910.119(o)(2) The compliance audit shall be conducted by at least one person knowledgeable in the process. 1910.119(o)(3)

[8] OSH Enforcement Procedures | CPL 02-02-073 - Inspection Procedures for 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases

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# TABLE OF CONTENTS (cont.) ## IX. Significant Changes. (cont.) Emergency responders must be made aware of the inventory in order to utilize the PPE and emergency response equipment effectively. (2) Citation Guidelines. If the ERP does not address the types and uses of PPE and emergency response equipment to be used, then cite (q)(2)(xi). - Failure to properly train employees in the selection and proper use of PPE shall be cited under 1910.120(q)(6). 13. (q)(2)(xii) Use of the Local Emergency Response Plan (LERP) or the State Emergency Response Plan (SERP). - Community emergency response agencies should be integral components of the community ERP. The community-wide ERP should spell out specific roles and responsibilities for various organizations or agencies, and will state which function each agency is expected to play in the event of an emergency. The employer's ERP may reference or otherwise include all or applicable sections of a LERP or SERP. D. Procedures for Handling Emergency Response – 1910.120(q)(3). - At ongoing or recently completed emergency response operations there is usually a shift in emphasis from the planning requirements of the standard toward the procedural requirements of the standard. An inspection of an actual emergency response should focus on the appropriate implementation of the ERP and compliance with the requirements of 1910.120(q)(3). - Upon arriving at an emergency response incident the CSHO should immediately seek out and report to the on-scene IC (or the on-scene coordinator (OSC) if the NCP is activated), or the appropriate official within the Incident Command System (ICS), such as the safety and health official (safety officer). The purpose of this meeting is to inform the IC/OSC of your presence and the purpose of the visit. (Note: OSHA Instruction HSO 01-00-001, National Emergency Management Plan (NEMP), clarifies procedures and policy for OSHA during response to nationally significant incidents. According t…

[9] Oregon OSHA Program Directive | National Emphasis Program (NEP): Process Safety Management of Highly Hazardous Chemicals

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# QE-21: Do recommendations from the facility siting study report need to be included on the PHA worksheet to comply with Sections 1910.119(e)(5) and 1910.119(e)(7) [PHA update/revalidation]? (cont.) ## M. 1910.119(m) Incident Investigation (cont.) In this scenario, employees are not responding to an incidental release and must comply with Section 1910.120(q). The employees respond from outside the machine room (i.e., outside the immediate release area) and perform actions to control the release including emergency shutdown of ammonia equipment and isolation of equipment or lines using existing valves. Oregon OSHA stated in its HAZWOPER compliance directive that limited actions, such as process operators turning valves during a release of hazardous materials, are regulated by Section 1910.120 [specifically Sections 1910.120(q)(6)(ii) or 1910.120(q)(6)(iii)]. The limited action taken by process operators must be addressed in the ERP required by Section 1910.120(q)(1). Program Directive A-206 3/01/2008, Hudson LoI 06/24/2003, and Paulsen LoI 10/02/2017 QN-04: Does Oregon OSHA require the employer to respond to a release of ammonia from their PSM-covered process? Response: No. Section 1910.120(q)(1) allows employers who will evacuate their employees from the danger area when an emergency occurs, and who do not permit any of their employees to assist in handling the emergency, to be exempt from the requirements of this paragraph if they provide an emergency action plan in accordance with OAR [redacted phone]. See QN-01 for guidance on responding to releases, including incidental releases. (NAME WITHHELD) LoI 01/26/1993 QN-05: Is there a requirement for two HHC release drills per year? Response: No. There is no explicit Oregon OSHA requirement for the number of HHC release drills to be conducted each year. However, if an employer has a PSM-covered process that requires its employees to take some action in response to the release of a HHC, these actions must be add…

[10] OSH Enforcement Procedures | CPL 02-01-065 - Process Safety Management (PSM) of Highly Hazardous Chemicals

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# D. 1910.119(d) – Process Safety Information (cont.) ## N. 1910.119(n) - Emergency Planning and Response (cont.) QN-04: Does OSHA require the employer to respond to a release of ammonia from their PSM-covered process? Response: No. Section 1910.120(q)(1) allows employers who will evacuate their employees from the danger area when an emergency occurs, and who do not permit any of their employees to assist in handling the emergency, to be exempt from the requirements of this paragraph if they provide an emergency action plan in accordance with Section 1910.38. See QN-01 for guidance on responding to releases, including incidental releases. ## (NAME WITHHELD) Lol 01/26/1993 QN-05: Is there a requirement for two HHC release drills per year? Response: No. There is no explicit OSHA requirement for the number of HHC release drills to be conducted each year. However, if an employer has a PSM-covered process that requires its employees to take some action in response to the release of a HHC, these actions must be addressed in the employer's PSM "procedures or plans" (i.e., Section 1910.119(f) — Operating Procedures, and Section 1910.119(n) Emergency - - Planning and Response). If the employer decides drills are needed to assure that employees are adequately trained in those procedures, then OSHA requires the employer to include those drills in their procedures and plans, and the employer must also ensure that employees are trained in those procedures. Section 1910.119(n) requires employers to establish and implement an EAP for the entire plant in accordance with Section 1910.38. Section 1910.119(n) also states, "Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in Section 1910.120(a), (p) and (q)." Therefore, if the employer's EAP required by Section 1910.38 contains provisions for conducting any type of drills, OSHA would require the employer to implement/conduct those drills. Likewise, emplo…

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