5 Common Misconception About OSHA 1910.38 Emergency Action Plans in Printing and Publishing

Printing and publishing facilities hum with high-speed presses, volatile inks, and stacks of flammable paper. Yet, when it comes to OSHA's 1910.38 Emergency Action Plan (EAP) standard, misconceptions persist that leave workers exposed. I've walked floors in SoCal print shops where a single solvent spill could turn chaotic without a solid EAP. Let's debunk the top five myths head-on.

Misconception 1: EAPs Are Just for Fires and Big Disasters

Many safety leads in printing plants think EAPs only kick in for infernos sparked by flammable solvents or massive paper jams. Wrong. OSHA 1910.38 requires plans for any emergency that could require evacuation, shelter-in-place, or employee accounting—like chemical releases from ink mixing or medical incidents near heavy machinery.

In one facility I audited, a minor hydraulic fluid leak led to slips and panic because no one knew the alarm protocols. Tailor your EAP to printing-specific hazards: solvent vapors, press entrapments, or even power outages trapping lifts. Research from the National Fire Protection Association (NFPA) shows non-fire emergencies cause 40% of printing incidents.

Misconception 2: A Generic Template Covers Your Shop

Grab a free EAP form online, tweak the company name, done. That's a recipe for non-compliance and worse. OSHA mandates site-specific elements: marked exit routes through maze-like press rooms, assembly points away from loading docks, and roles for everyone from operators to managers.

• Include floor plans showing ink storage and waste areas.
• Account for shift workers on 24/7 runs.
• Specify rescue procedures for confined spaces like dryer tunnels.

Generic plans fail audits—I've seen printing firms fined $14,000 for this alone. Customize based on your layout; OSHA's eTool for printing offers free templates as a starting point.

Misconception 3: Posting the Plan Is Enough—No Training Needed

Pin the EAP on the break room wall and call it trained. Nope. 1910.38(b)(4) demands initial and updated training so employees understand signals, routes, and their roles. In publishing houses with transient contractors fixing bindery lines, this is critical.

Picture this: A fire alarm blares during a color run, but half the crew ignores it, assuming it's routine equipment noise. We recommend annual drills with realistic scenarios—ink fires or evacuations past guillotines. Studies from the Bureau of Labor Statistics indicate trained sites cut evacuation times by 50%.

Misconception 4: Small Print Shops Don't Need Designated Coordinators

"We're only 50 people—no need for an EAP boss." Think again. The standard requires at least one person responsible for accounting and alerting authorities, scaling with your operation. In mid-sized publishing ops, this coordinator manages multi-building evacuations or coordinating with off-site warehouses.

I've consulted shops where the owner doubled as coordinator, leading to overlooked headcounts during drills. Appoint backups, train them on two-way radios amid noisy presses, and review annually. It's not bureaucracy; it's the line between orderly exit and tragedy.

Misconception 5: Annual Review Suffices Without Testing

Update the EAP once a year, file it, forget it. OSHA requires more: test via drills and revise post-incident or layout changes—like new digital presses altering routes. Printing's dynamic environment demands quarterly walkthroughs.

Post-drill, debrief: Did pre-press crews block exits with pallets? Adjust accordingly. NFPA 1620 guides pre-incident planning for industrial sites like yours. Limitations? Drills can't simulate everything, but they're your best prep—far better than winging it when seconds count.

Rectify these myths to shield your printing and publishing team. Reference OSHA's full 1910.38 text and their printing industry resources for precision. Your EAP isn't paperwork—it's the blueprint that keeps presses rolling safely.