Only if an OSHA standard in part 1910 requires one for your workplace. When one does, section 1910.38 governs it, and an employer with 10 or fewer employees may share the plan orally instead of in writing.
Reviewed October 17, 2026
Check whether a plan is required first
Section 1910.38(a) requires an emergency action plan whenever another OSHA standard in part 1910 requires one. §1910.38(a)
A plan under this section must be written, kept at the workplace and open to employees for review. The exception is the oral option for employers with 10 or fewer employees. §1910.38(b)
Describe the work you do, your workplace and your emergency setup. Ask a qualified reviewer which standards apply to you. Headcount alone does not answer that question.
Plan for people, not just paper
The employer must designate and train employees to help others leave safely and in an orderly way. §1910.38(e)
The employer must review the plan with covered employees when the plan is developed or they are first assigned a job. It must be reviewed again when their plan duties change and when the plan changes. §1910.38(f)(1)–(3)
If you choose a written version, name the person who keeps it and say where staff can read it. Ask your reviewer to check other applicable rules before you settle on a format.
Questions and answers
Does having 10 or fewer employees remove the planning task?
No. The small-employer option only lets you share the plan orally. Whether you need a plan, and what else applies, are separate questions.
About Bill Stomp
Bill Stomp built Propane Safety Pro. He is a war veteran who ran over 87 propane branch offices across 12 states, and he has helped more than 200 propane companies improve their profits, sales, safety and operations.
Next step
Got questions about which workplace programs you need on paper? Start with the Policies & Procedures manual for propane companies.
General information, not legal advice.