Last reviewed 6 August 2020
Employers are required to have plans for evacuation in emergencies, but some workers — such as agency and contract workers who work outside of normal working hours — can be forgotten.
Regulation 8 of the Management of Health and Safety at Work Regulations 1999 requires employers to establish procedures for dealing with “serious and imminent danger”, which could include situations such as terrorist incidents, gas leaks, flooding, etc.
Regulation 9 requires the employer to arrange any necessary contacts with external services — normally the emergency services such as the Fire and Rescue Service — “particularly as regards first aid, emergency medical care and rescue work”. For many employers, this may be as simple as knowing the appropriate telephone numbers to call in an emergency.
Depending on the nature of the risk, the involvement of other services may be necessary. For example, chemical plants that are subject to the Control of Major Accident Hazards Regulations (COMAH) are required to provide a safety case, in which the provisions of emergency evacuation procedures can be extensive. In these cases, a serious incident could significantly affect the surrounding areas and population, necessitating substantial planning with a number of external organisations.
Specifically in relation to fire, the Regulatory Reform (Fire Safety) Order 2005 put the onus on the employer to assess the risk of fire within the premises and then apply the appropriate control measures, including evacuation procedures. This Order applies to England and Wales.
A similar requirement applies to Scotland through the Fire Safety (Scotland) Regulations 2006 and in Northern Ireland the Fire and Rescue Services (Northern Ireland) Order 2006/Fire Safety Regulations (Northern Ireland) 2010.
The emphasis of the above legislation is on how to prevent the occurrence of hazardous situations. However, it is recognised that things can go wrong. Employers are therefore required to have plans for evacuation in emergencies.
This includes ensuring that workers who may not be in the mainstream of employees, that is those working out of hours, are taken into account when considering emergency evacuation plans.
Getting everybody out during emergency evacuations
A comprehensive emergency evacuation plan should exist in every workplace to ensure that all people within the premises can safely evacuate in the event of an emergency. For small premises this will be straightforward. For multi-storey buildings within large work areas with a variety of industrial processes, such a plan may be quite complex. The plan should include:
how the instruction to evacuate can be communicated effectively and in a timely manner
what specific roles and responsibilities are required to be undertaken to enable safe evacuation
what instructions need to be given in order for people to respond effectively including those with specific roles and responsibilities
what arrangements are required for assisting those who may be vulnerable or have mobility problems
where to evacuate to (the place of safety/assembly point) and how this is to be achieved
what special arrangements need to be made for the welfare of evacuees, particularly those who are vulnerable or may have suffered injury during the incident/evacuation
what arrangements, if any, could be made to record who has evacuated and where they have gone to.
Over the last 15 years, there has been a greater use of contractors, agency labour and people who in particular have fragmented working patterns, eg cleaners or maintenance staff who work at different premises in any given week. Similarly, there are people who work in isolated parts of a workplace who may not be in close contact with fellow workers for significant periods. Contractor employees, for instance, may be required to work at remote locations to maintain plant and equipment.
Similarly, there may be workers whose hours coincide with few people being in the work area, eg cleaners doing a few hours in premises at night when day workers have left. Security workers may be on-site during periods at night when few or no other people are present. It follows that people who may only occasionally work in the premises or be present when few people are working there — such as at night or at the weekend — may not be as familiar with the emergency procedures as those working there regularly. It is also foreseeable that in an emergency, agency/contractor workers may easily be forgotten if specific provisions are not made to cover them.
Therefore, it can be seen that if emergency evacuation plans are to be effective, they must take into account all those workers — and others — who may be on the premises at any time. Agency or contract workers will need information about emergency procedures and what to do in the event of emergencies. It is the employer’s responsibility to ensure that such workers understand the arrangements. This is particularly important at night times and weekends.
What measures will be needed to take into account agency or contract workers on the premises outside “normal hours”? Specific control measures will depend on the analysis done during the risk assessment process. However, the following are some measures that organisations have taken.
Specific information, instruction and training. In addition to the general information regarding emergency evacuation, eg identifying emergency exits and what the fire alarm sounds like, specific training may be given on what agency/contract workers need to do during “out of normal hours”. This may include specific signing on/off work procedures so that supervisors, etc know exactly where that person is working. Where lone working may occur, the individual needs to know what to do in the event of an emergency and who to contact.
Communications. It may be necessary to provide increased communication measures to people who may be working in isolated areas or on their own. This can include: two-way radios or mobile phones for direct communication, a planned call-back procedure so that the person “checks in” at regular intervals, a lone-worker alarm device so that an automatic alarm is raised in the event of an injury or other emergency, or even fitting the person with direct audio/video devices so that they are in continuous communication with a central, monitored point.
Buddy system. This is used in particular where there may be a vulnerable person working who may require assistance. As the name, suggests another person acts as a “buddy” to the individual so that in an emergency they can help the second person escape. This could be used for agency/contractor workers who may operate alone at times when fewer people operate in the premises.
Increased supervision. When agency/contractor workers are operating out of normal hours, supervision may need to be increased to ensure their work location is monitored more frequently. In an emergency, the supervisor would know exactly where they are and check that they have evacuated the building.
No matter how well designed and thought-out an evacuation plan is, it cannot be considered reliable until it is tested and has proved to be effective, especially since false confidence may be placed in the integrity of a written plan. Testing has a number of purposes:
verifying that the plan incorporates all critical elements necessary to enable evacuation to a reasonably safe place
highlighting assumptions that may be made about the plan at the development stage
practising the effectiveness of any adjustment made or use of specialist equipment provided
demonstrating competence after training of those with specific responsibilities
instilling confidence in all those required to react to the plan
validating the overall effectiveness of the plan so as to meet statutory obligations.
In a site that might be classified as hazardous, there needs to be some co-ordination between the organisation and the agency or contractor whose workers may be on the client’s site regarding general health and safety issues. However, it is the employer in control of the site who must ensure that anybody coming onto the site is fully informed about the emergency evacuation procedures, in addition to any other related emergency provisions.
It can be seen that for agency or contractor workers who need to be on the site at night and during weekends, the emergency evacuation procedures must include any specific measures to ensure their safe evacuation. During an emergency is not the time to find out that agency or contract workers have been forgotten.