Does OSHA require accounting for employees after an evacuation?

Yes. 29 CFR 1910.38(c)(4) lists procedures to account for all employees after evacuation as a minimum required element of an emergency action plan. It sits alongside reporting procedures, evacuation procedures and exit route assignments, procedures for employees performing critical operations, rescue and medical duties, and contact information.

Does the emergency action plan have to be written?

Under 1910.38(b) the plan must be in writing, kept in the workplace, and available to employees for review. An employer with 10 or fewer employees may communicate the plan orally instead.

What does accounting for all employees actually mean?

It means knowing, after an evacuation, which people were on site and confirming where each one is. That requires a current list of who is present, including visitors and contractors, and a way to check names against it at the assembly area, not a static roster printed at the start of the shift.

Who has to be trained under 1910.38?

1910.38(e) requires the employer to designate and train employees to assist in a safe and orderly evacuation. 1910.38(f) requires the plan to be reviewed with each employee when the plan is developed, when their responsibilities change, and when the plan itself changes.

Emergency preparedness

Employee accountability after evacuation: what OSHA 1910.38 requires.

Most emergency action plans get the alarm and the exit routes right, then handle the headcount with a sentence. But accounting for everyone is not an implied good practice: it is one of six minimum elements OSHA requires the plan to contain, and it is the element a printed roster cannot satisfy.

What the standard actually says

29 CFR 1910.38(c) sets the minimum elements of an emergency action plan. There are six, and the fourth is the one this article is about:

(c)(1) Procedures for reporting a fire or other emergency.
(c)(2) Procedures for emergency evacuation, including type of evacuation and exit route assignments.
(c)(3) Procedures for employees who remain to operate critical operations before they evacuate.
(c)(4) Procedures to account for all employees after evacuation.
(c)(5) Procedures to be followed by employees performing rescue or medical duties.
(c)(6) The name or job title of every employee who may be contacted for more information about the plan.

Two more clauses matter. 1910.38(b): the plan must be in writing, kept in the workplace, and available to employees for review, though an employer with 10 or fewer employees may communicate it orally. 1910.38(e): the employer must designate and train employees to assist in a safe and orderly evacuation. 1910.38(f) requires the plan reviewed with each employee when it is developed, when their responsibilities change, and when the plan changes.

Why a printed roster does not satisfy (c)(4)

Accounting for all employees means knowing who was on site and confirming where each of them is. A roster printed at shift start answers the first half and is already wrong by mid-morning:

People left and arrived. Someone went to a customer, someone came back early, someone called in and the roster never knew.
Visitors and contractors are not on it. They are on site, they are in the building, and the plan has to account for them even though the payroll roster never will.
The list is inside the building. If it lives at the front desk, the evacuation that made you need it also made it unreachable.
Nothing records the outcome. After the all-clear, a paper count leaves no evidence the accounting happened, which is exactly what an OSHA inspector or an insurer asks about afterwards.

What a working accountability procedure looks like

A live on-site list. Employees, visitors, contractors and delivery drivers in one place, current to the minute, because the count is a subtraction: everyone known to be on site, minus everyone confirmed at the assembly area, equals the people still unaccounted for.
The list reachable outside the building. On the phones of the people running the count, not on a clipboard at reception.
Named responsibility per area. 1910.38(e) asks for designated, trained employees; give each of them a zone and a deputy.
An exception for every name. Off site, working remotely, at lunch, left early: each unchecked name needs a reason, not an assumption.
Escalation for the genuinely unaccounted. A name with no reason goes to the incident commander with a last known location, which is what responding fire crews ask for on arrival.
A record of what happened. Alarm time, time to full account, headcount, unresolved names and how each closed. Both for the drill review and for the question that comes later.

Where this bites in practice

Three situations turn the paperwork question into a real one:

Multi-employer sites. Contractors working for someone else are in your building during your evacuation. Whose list are they on?
Shift changeover. The moment of peak occupancy and peak roster inaccuracy, simultaneously.
After a real event. The investigation asks how you knew everyone was out, and the answer is whatever your system recorded at the time.

Account for everyone, from a phone.

Employees, visitors and contractors on one live list your evacuation leads can reach outside the building, with the count recorded automatically.

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