A fire emergency plan translates the fire risk assessment into action. Where the risk assessment identifies what could go wrong and why, the emergency plan specifies what will happen, who will do it, and in what sequence when a fire occurs. The two documents are inseparable: a risk assessment without an emergency plan identifies hazards without resolving them; an emergency plan without a risk assessment addresses procedures without being grounded in the specific hazards of the event.

Fire emergency plans for assembly occupancies are required by both the International Fire Code and NFPA 101, and their required content is specifically defined. Understanding what must be in the plan — and what distinguishes an effective plan from a compliance document that will not actually guide anyone during an emergency — is one of the most important aspects of event fire safety planning.

The Legal Requirement

OSHA’s Emergency Action Plan standard (29 CFR 1910.38) requires that employers with ten or more employees maintain a written emergency action plan that is available for employee review. The plan must address procedures for reporting fires and other emergencies, evacuation procedures and route assignments, procedures for employees who must operate critical equipment before evacuating, procedures for accounting for all employees after evacuation, and identification of rescue and medical duties (Occupational Safety and Health Administration [OSHA], 2016).

The IFC and NFPA 101 impose additional requirements specifically for assembly occupancies, addressing both the fire evacuation plan (the operational document used during an incident) and the fire safety plan (the broader planning document kept on file with the AHJ and building management) (International Code Council [ICC], 2021a; National Fire Protection Association [NFPA], 2021).

The Fire Evacuation Plan: Required Content

NFPA 101 specifies the minimum contents of a fire evacuation plan for assembly occupancies (NFPA, 2021):

Emergency Egress Routes

The plan must specify the emergency egress and escape routes and whether evacuation is to be complete (all occupants evacuate the entire building or site) or by selected areas only. In large multi-zone events, it may be appropriate to evacuate specific areas while others remain in place — but this requires pre-planning, staff training, and a communication system capable of directing different actions in different areas simultaneously (NFPA, 2021).

Critical Equipment Procedures

Some equipment cannot be safely abandoned during an evacuation — power systems that, if simply cut, could create additional hazards; communication infrastructure needed to direct the evacuation; mechanical systems that must be shut down in a specific sequence. The plan must identify this equipment, specify who is responsible for each system, and describe the procedure and the maximum time allowed before that person must also evacuate (NFPA, 2021; OSHA, 2016).

Assisted Rescue Procedures

Not every person can evacuate independently. People using wheelchairs, people with mobility limitations, people with visual or hearing impairments, and people who are injured or become incapacitated during the event may require assistance. The plan must specify the procedure for providing assisted rescue, including designated areas of refuge for those awaiting assistance, the two-way communication system connecting those areas to the command center, and the staff assigned to provide assistance (NFPA, 2021; ADA National Network, 2010).

Personnel Accountability

After evacuation, the plan must specify how the organizer will account for all staff, volunteers, and contractors. This requires knowing who was assigned to what area and confirming that each person has exited. The accountability procedure should designate specific assembly areas for staff, a method for checking off each person against an on-site roster, and a procedure for reporting to the incident commander that all staff are accounted for — or that specific individuals are missing (OSHA, 2016).

Rescue and Medical Assignments

The plan must identify the staff assigned to rescue or emergency medical duties and the extent of their training and authority. This does not require every staff member to be a paramedic — it requires that someone has a designated role for each function and knows what that role is before an emergency occurs (OSHA, 2016; NFPA, 2021).

Notification Procedures

The plan must specify the preferred and alternative means of notifying occupants of a fire or emergency and the preferred and alternative means of notifying the fire department. For events using coded announcement systems (where staff receive a coded message through the radio system rather than a public alarm), the code words and their meanings must be documented in the plan and communicated to all relevant staff (NFPA, 2021).

Emergency Voice/Alarm Communication

Where an emergency voice/alarm communication system (EVACS) is provided, the plan must describe the alert tone used and the preprogrammed voice messages available. For events, this section should specify who has authority to activate different levels of the communication system — who can initiate a coded staff alert, who can authorize a general public announcement, and who can authorize the full evacuation announcement (NFPA, 2021; NFPA, 2022a).

The Fire Safety Plan: What It Must Include

The fire safety plan is the broader planning document that supplements the fire evacuation plan. Its required contents under NFPA 101 include (NFPA, 2021):

• Procedures for reporting a fire or other emergency
• Life safety strategy and procedures for notifying, relocating, or evacuating occupants, including those who need assistance
• Site plans identifying: the occupant assembly point, the locations of fire hydrants, and normal routes for fire department vehicle access
• Floor or site plans identifying: exits, primary and secondary evacuation routes, accessible egress routes, areas of refuge, exterior areas for assisted rescue, manual fire alarm boxes, portable fire extinguishers, occupant-use hose stations, and fire alarm annunciators and controls
• A list of major fire hazards associated with the event
• Identification and assignment of personnel responsible for maintenance of fire protection systems and equipment
• Identification and assignment of personnel responsible for fuel hazard control and housekeeping

The site plan is one of the most operationally important elements of the fire safety plan. A single well-drawn site plan that shows all exits, extinguisher locations, alarm stations, fire department access routes, hydrant locations, and assembly areas gives every responding emergency service agency the information they need to act quickly and effectively. This document should be shared with the local fire department before the event (FEMA, 2010).

ADA Requirements in the Fire Emergency Plan

The Americans with Disabilities Act Standards for Accessible Design (2010) require that assembly occupancies provide accessible means of egress, including areas of refuge with two-way communication systems for people who cannot use stairways, and exterior areas for assisted rescue at ground-floor accessible exits. The fire emergency plan must specifically address evacuation of people with disabilities — not leave it as an afterthought to be resolved on the day of an incident (ADA National Network, 2010; NFPA, 2021).

For events with general admission audiences, the organizer typically does not know in advance who among the audience may need evacuation assistance. Staff must be trained to identify and assist individuals who need help during an evacuation, and areas of refuge must be available and signed. The pre-event public announcement should include information about how to request evacuation assistance, and event staff positioned at area of refuge locations must know what to do when someone uses them (NFPA, 2021).

Communicating the Plan to Staff

A plan that is not known to the people who must implement it is not a functional plan. OSHA requires that the emergency action plan be reviewed with each covered employee when the plan is developed, when the employee’s responsibilities under the plan change, and when the plan is updated (OSHA, 2016). For event staff, this means a pre-event briefing that covers each person’s specific role — not a general statement that “there is a plan.”

Pre-event briefings should address:

• Each staff member’s specific position and their assigned evacuation role for that position
• The coded communication system: what each code means, how to activate it, and what to do when it is activated
• The location of the nearest fire extinguisher, alarm station, and AED to each work area
• The assembly area for staff and how to report to the accountability system after evacuation
• Who has authority to initiate various levels of the emergency response

Briefings should be documented. Documentation demonstrates that training was provided, supports insurance and regulatory requirements, and creates a record that can be reviewed after an incident to assess whether the briefing was adequate (OSHA, 2016; NFPA, 2022d).

Approval at the Senior Level

NFPA 1600 and NFPA 101 both identify senior organizational leadership as accountable for emergency plan approval. The fire emergency plan should be signed off at the highest available level of organizational authority for the event — the event director, venue general manager, or equivalent. Senior leaders who have approved the plan are more likely to be aware of their authority during an incident and less likely to hesitate when the plan requires them to make a difficult decision, such as stopping the show or ordering an unplanned evacuation (NFPA, 2022d; NFPA, 2021).

References

ADA National Network. (2010). ADA standards for accessible design. U.S. Department of Justice. https://www.ada.gov

Federal Emergency Management Agency. (2010). Special events contingency planning job aids manual. U.S. Department of Homeland Security.

International Code Council. (2021a). International fire code. ICC.

National Fire Protection Association. (2021). NFPA 101: Life safety code. NFPA.

National Fire Protection Association. (2022a). NFPA 72: National fire alarm and signaling code. NFPA.

National Fire Protection Association. (2022d). NFPA 1600: Standard on continuity, emergency, and crisis management. NFPA.

Occupational Safety and Health Administration. (2016). 29 CFR 1910.38: Emergency action plans. U.S. Department of Labor.