Emergency Action Plans, Spill Response, and Incident Reporting
Objective. Students will execute a solvent spill response and evacuation using the plant's written Emergency Action Plan and a spill kit, and will correctly complete an OSHA First Report of Injury/Illness form for a simulated exposure incident.
This lesson, its worked examples and its practice questions has not yet been verified by a credentialed professional in the field or by a certification or approval body. It is a study draft and may contain errors. Do not use it as instructions for work on a job site or on live equipment. Always follow your instructor, your supervising professional, and current official references and regulations.
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Why Emergency Preparedness Matters in a Dry Cleaning Plant
Dry cleaning shops and industrial laundries handle solvents, high-temperature equipment, and pressurized systems every day. When something goes wrong—a hose fitting fails, a worker breathes solvent vapor, or a spill reaches the drain—the difference between a near-miss and a serious injury is almost always how well everyone knows the plan before the emergency happens. Federal law requires most workplaces to have a written Emergency Action Plan (EAP), and OSHA's recordkeeping rules set clear requirements for documenting injuries and illnesses. This lesson walks you through both.
The Emergency Action Plan (EAP)
An EAP is a written document that tells every employee exactly what to do when an emergency occurs. Under OSHA's emergency action plan standard, employers with ten or more employees must keep the plan in writing; smaller shops must at minimum communicate the plan orally to all employees. At minimum, a compliant EAP for a dry cleaning operation must include:
- Procedures for reporting a fire or other emergency (who calls 911, who notifies the plant manager)
- Evacuation procedures and route assignments, including a floor plan showing exits and assembly points
- Procedures for employees who must stay behind to operate critical equipment before evacuating
- Accounting for all employees after evacuation at a designated assembly area
- Rescue and medical duties for any employees assigned those roles
- The name or title of the person employees can contact for more information
In a solvent-handling environment, the EAP should also address solvent-specific hazards: where the Safety Data Sheets (SDS) are kept, the location of emergency eyewash and shower stations, and at what point a spill or exposure requires calling 911 versus handling internally.
Decision Sequence for a Solvent Exposure Incident
If a coworker reports dizziness, headache, or eye irritation in the solvent room, follow this sequence:
1. Remove the person from the exposure area immediately. Get them to fresh air. Do not wait to confirm the cause.
2. Alert a supervisor or the designated emergency contact. Announce the situation clearly; do not assume someone else already knows.
3. Consult the SDS for the solvent involved to identify first-aid steps and exposure limits.
4. Provide first aid as directed—flush eyes with water for the time stated on the SDS if eyes were exposed.
5. Call 911 if the person loses consciousness, cannot walk, has severe respiratory distress, or if the SDS directs medical attention for the level of exposure.
6. Account for all workers at the assembly point if the area must be evacuated.
7. Do not re-enter the area until it has been ventilated and cleared by a competent person.
Spill Response: PERC and Other Solvents
Perchloroethylene (PERC) is a chlorinated solvent classified as a hazardous waste and a probable human carcinogen. Even a small liquid spill must be treated as a hazardous materials event. The general spill response sequence for a small, contained spill:
1. Don PPE before approaching the spill. For PERC: chemical-splash goggles, a face shield if splash risk is high, chemical-resistant gloves rated for chlorinated solvents, and a solvent-resistant apron. Check the SDS for your specific solvent—PPE requirements vary.
2. Eliminate ignition sources if the solvent is flammable. PERC is not flammable, but other solvents used in laundry (such as some hydrocarbon solvents) are.
3. Contain the spill using absorbent pads or granular absorbent from the spill kit. Work from the outside edge inward to prevent spreading.
4. Collect the saturated absorbent into a compatible, sealed disposal bag or container.
5. Label the waste container immediately. The label must identify the contents as hazardous waste and include the date accumulation began, in accordance with EPA hazardous waste regulations.
6. Complete a spill log entry recording the date, time, solvent involved, estimated quantity, cause, response actions taken, and the names of responders.
7. Do not remove PPE or gloves until decontamination is complete. Remove outer gloves by turning them inside-out; never touch the contaminated outer surface with bare skin.
8. Store waste for proper disposal through a licensed hazardous waste hauler.
Never wash PERC or other regulated solvents down a floor drain. Doing so violates EPA regulations and can result in significant fines.
OSHA Recordkeeping and Incident Reporting
OSHA requires covered employers to record work-related injuries and illnesses that meet certain criteria on the OSHA 300 Log. An injury or illness is recordable if it results in: days away from work, restricted duty, transfer to another job, medical treatment beyond first aid, loss of consciousness, or diagnosis of a significant injury or illness by a health-care professional.
The First Report of Injury/Illness (sometimes called the OSHA 301 equivalent, or the state workers' compensation first report form) must be completed for each recordable incident. Required fields typically include: employee information, date and time of incident, location, description of what happened, the body part affected, the object or substance involved, and the name of the treating physician or facility.
Reporting deadlines you must know:
- Any work-related fatality must be reported to OSHA within 8 hours.
- Any in-patient hospitalization, amputation, or loss of an eye must be reported to OSHA within 24 hours.
- These reports can be made by phone to the nearest OSHA office or through OSHA's online reporting portal.
Solvent vapor eye exposure that leads to hospitalization triggers the 24-hour reporting requirement. Eye contact with liquid solvent that is treated with first aid only (flushing) and results in no days away from work may not meet recordability criteria—evaluate each case against the full OSHA recordability criteria.
Staying Ready
Post the EAP, evacuation route map, and emergency phone numbers where every worker can see them. Inspect your spill kit monthly—absorbent materials have a finite capacity and disposal bags degrade. Run a drill at least annually. The few minutes it takes to practice today are the minutes that protect a coworker tomorrow.
Key terms9
Materials: Model plant Emergency Action Plan (one-page handout); floor plan with evacuation routes; spill kit (absorbent pads, disposal bags, compatible gloves, splash goggles); colored tape for spill zone; drill scoring rubric; blank OSHA First Report of Injury/Illness practice forms; OSHA recordkeeping regulation overview card; stop watch
Check: Spill drill rubric: student completes all required containment and disposal steps in correct PPE within the allotted time; any step that would have worsened exposure (e.g., removing PPE before decontamination) results in automatic repeat. Incident form: completed accurately with correct recordability determination—pass mark is zero errors in required fields and correct reporting threshold identified.
Practice check8
Answer each question, then check it. Nothing is recorded; this is your own practice.
