Fire Curtain Safety: Essential Compliance and Best Practices for Theater Administrators
Fire curtains, also called fire safety curtains or proscenium curtains, are critical life-safety components in theaters designed to compartmentalize fire and smoke, preventing their spread from the stage to the audience. When properly installed, inspected, and maintained, fire curtains provide essential time for evacuation and emergency response. When neglected, they represent catastrophic life-safety failures. Understanding regulatory requirements and implementing comprehensive maintenance programs are non-negotiable administrative responsibilities.
Throughout this document you will see references to an annual inspection. The link at the top of this page will connect you with our recommended, ETCP Certified, Inspector(s). Our inspector will also connect you with the best Consultant or Contractor for your theater if repairs or replacement is necessary.
Regulatory Framework: Understanding Your Obligations
Fire curtain requirements derive from multiple sources, creating overlapping obligations that administrators must navigate:
NFPA 101: Life Safety Code
The National Fire Protection Association’s Life Safety Code (NFPA 101) Section 12.4.5 establishes fundamental requirements for proscenium opening protection in assembly occupancies. These requirements specify when fire curtains are required, acceptable alternatives (such as approved water curtain deluge systems combined with draft curtains), and performance criteria.
Key provisions include requirements for smoke pockets above the proscenium opening, automatic closing mechanisms activated by approved detection systems, and manual emergency operation capability.
NFPA 80: Standard for Fire Doors and Other Opening Protectives
NFPA 80 governs inspection, testing, and maintenance procedures for fire curtains once installed. Section 5.2.4 establishes specific inspection frequencies, testing methodologies, and documentation requirements for fire curtains as opening protectives.
Critical requirement: Monthly operational testing and annual inspection by qualified inspectors.
NFPA 701: Standard Methods of Fire Tests for Flame Propagation
NFPA 701 establishes flame resistance testing requirements for fire curtain fabric materials. Curtains must be tested and certified using prescribed test methods, with periodic re-certification required as flame-retardant treatments can degrade over time.
ANSI E1.4: Manual Counterweight Rigging Systems
The Entertainment Services and Technology Association (ESTA) Technical Standards Program develops American National Standards Institute (ANSI) approved standards for the entertainment industry. ANSI E1.4 addresses manual counterweight rigging systems, which are frequently integrated with fire curtain installations in theaters. This standard establishes design, installation, inspection, and maintenance requirements for counterweight systems that may support or interact with fire curtain mechanisms (ANSI, 2022a).
Understanding E1.4 requirements is essential when fire curtains utilize counterweight systems for operation, as the rigging system’s structural integrity directly affects fire curtain reliability.
ANSI E1.43: Entertainment Technology—Performer Flying Systems
ANSI E1.43 establishes requirements for performer flying systems but contains relevant provisions for any overhead rigging system in entertainment venues (ANSI, 2016). The standard’s inspection protocols, structural safety factors, and maintenance requirements apply to fire curtain rigging components and support structures.
ANSI E1.6-1: Entertainment Technology—Powered Hoist Systems
Many modern fire curtains utilize powered hoist systems for raising and lowering rather than manual counterweight systems. ANSI E1.6-1 establishes design, installation, inspection, operation, and maintenance requirements for powered entertainment technology hoists (ANSI, 2022b). Compliance with E1.6-1 ensures that motorized fire curtain systems meet industry safety standards for powered lifting equipment.
Local Fire Codes and Authority Having Jurisdiction (AHJ)
State and local fire codes may impose requirements exceeding NFPA minimums. Your local fire marshal serves as the Authority Having Jurisdiction, with final approval authority over fire curtain installations, modifications, and operational compliance. Building occupancy permits may be contingent on fire curtain compliance verification.
Installation Requirements: Getting It Right From the Start
Proper installation establishes the foundation for effective fire curtain operation throughout the system’s service life.
Qualified Installation Personnel
Fire curtain installation requires specialized expertise combining theatrical rigging knowledge with fire protection system understanding. Qualified installers typically possess:
- Manufacturer-specific training and certification for the fire curtain system being installed
- ETCP Theatre Rigger certification or equivalent theatrical rigging credentials demonstrating knowledge of ANSI E1 standards
- General contractor licensing as required by state and local jurisdiction
- Documentation of prior fire curtain installation experience
- Familiarity with ANSI E1.4 (counterweight systems) or E1.6-1 (powered hoist systems), depending on fire curtain operational mechanism
Verification: Request copies of installer credentials, manufacturer authorization letters, and references from comparable installations before authorizing work.
Design and Engineering Requirements
Fire curtain installations require engineering analysis addressing:
- Structural adequacy of support points and building structure for static and dynamic loads, applying appropriate safety factors from ANSI E1.43 (typically 8:1 for non-entertainment loads)
- Smoke pocket design preventing smoke bypass around curtain edges (NFPA 101 requirement)
- Integration with fire alarm and detection systems for automatic activation
- Clearance requirements from rigging, lighting, scenery, and other stage systems
- Manual release mechanism location and accessibility for emergency operation
- Compliance with rigging system standards (E1.4 for counterweight systems, E1.6-1 for powered systems)
Most jurisdictions require Professional Engineer (PE) stamped drawings and calculations for fire curtain installations, submitted to the fire marshal for approval prior to installation. Engineers should demonstrate familiarity with both building codes and ANSI E1 entertainment technology standards.
Labeling and Documentation Requirements
Compliant fire curtain installations include permanent labeling indicating:
- Manufacturer name and model designation
- Date of manufacture
- NFPA 701 flame resistance test certification (laboratory name, test method, certification date)
- Flame-retardant treatment information (chemical type, treatment date, manufacturer)
- Installation date and installing contractor
- Required inspection and testing intervals
- Working load limit and design load information (per ANSI E1.4 or E1.6-1)
- Serial numbers for hoists or mechanical systems
Documentation to maintain:
- As-built drawings showing fire curtain location, dimensions, and integration with building systems
- Manufacturer installation manuals and operation instructions
- PE calculations and structural certification
- Fire marshal approval documentation
- Certificate of occupancy reflecting fire curtain compliance
- ANSI E1 compliance documentation for rigging or hoist systems
- Load testing certificates for structural support points
Integration with Fire Protection Systems
Fire curtains rarely function in isolation. Complete proscenium fire protection systems typically include:
Automatic fire detection systems triggering curtain release (heat detectors, smoke detectors, or both per AHJ requirements)
Deluge sprinkler systems providing water curtain backup protection (required in many jurisdictions per NFPA 13)
Fire alarm system integration ensuring coordinated activation and notification
Emergency power backup for motorized fire curtain operation during power failures
Smoke control systems managing smoke movement to maintain tenable conditions during evacuation
Administrators must understand that fire curtain compliance extends beyond the curtain itself to encompass these integrated systems.
Inspection and Testing: Maintaining Operational Readiness
NFPA 80 establishes mandatory inspection and testing protocols ensuring fire curtains remain operational throughout their service life. ANSI E1 standards provide additional guidance for rigging and hoist components.
Monthly Operational Testing
Frequency: Monthly
Performed by: Trained theater technical staff familiar with fire curtain operation and basic rigging system inspection per ANSI E1.4 or E1.6-1
Procedure:
- Visually inspect curtain fabric for tears, damage, or deterioration
- Check guide tracks and seals for obstructions or damage
- Verify emergency manual release mechanism accessibility and signage
- Inspect rigging components per ANSI E1 standards:
- For counterweight systems: Inspect wire rope for broken wires, kinks, or wear (E1.4)
- For powered systems: Verify hoist operational indicators, listen for unusual sounds (E1.6-1)
- Check sheaves, blocks, and hardware for wear or damage
- Test curtain operation from fully open position using manual release
- Verify curtain travels full distance and forms complete seal at stage floor
- Observe closing time (typically 20-30 seconds for full travel) and listen for unusual sounds indicating mechanical issues
- Reset curtain to open position and verify proper latching
- Test automatic activation system (coordination with fire alarm technician recommended)
- Document testing date, personnel conducting test, observations, and any deficiencies
Critical: Monthly testing identifies deterioration before it becomes life-safety failure. Skipping monthly testing violates NFPA 80 requirements and creates liability exposure.
Annual Comprehensive Inspection
Frequency: Annually
Performed by: Qualified fire curtain inspector (manufacturer-authorized technician, specialized rigging inspector with ETCP certification or equivalent, or fire protection system inspector with fire curtain expertise and familiarity with ANSI E1 standards)
Inspection scope:
- Complete operational testing including manual and automatic activation
- Detailed fabric inspection for flame resistance degradation, tears, or damage
- Mechanical component inspection per ANSI E1.4 (counterweight systems) or E1.6-1 (powered hoists):
- Wire rope non-destructive testing and retirement criteria assessment
- Sheave groove wear measurement
- Bearing condition and lubrication
- Counterweight arbor inspection (if applicable)
- Hoist load testing and brake verification (if applicable)
- Structural support point inspection
- Electrical system inspection (controls, interlocks, power supply, limit switches)
- Smoke pocket and seal integrity verification
- Clearance verification from rigging and stage systems
- Integration testing with fire alarm and detection systems
- Documentation review (previous inspection reports, maintenance records)
- Flame resistance re-certification assessment (NFPA 701 compliance verification)
- Verification that working loads remain within design parameters
Deliverable: Written inspection report documenting findings, deficiencies, and corrective action recommendations. Serious deficiencies may require immediate operational restrictions until corrected. Report should reference applicable NFPA and ANSI standards.
ESTA Inspector Program Resources
The ESTA Technical Standards Program maintains resources for qualified inspectors including:
- Interpretation documents clarifying ANSI E1 standard requirements
- Training materials for rigging and hoist system inspection
- Technical bulletins addressing common inspection challenges
- Continuing education opportunities for entertainment technology professionals
Engage inspectors who demonstrate current knowledge of ESTA standards through participation in continuing education programs or professional certifications like ETCP.
Documentation Requirements
NFPA 80 and ANSI E1 standards require maintaining written records of:
- All monthly operational tests (date, personnel, findings)
- Annual inspection reports with qualified inspector signature and credentials
- All maintenance, repairs, or component replacements
- Flame resistance re-certification test results
- Fire marshal inspections and approvals
- Load testing results for structural components
- Wire rope or hoist replacement documentation with specifications
- Modifications to fire curtain or rigging systems with engineering approval
Retention: Maintain records for the life of the fire curtain plus a minimum of one year after replacement. Many jurisdictions require longer retention periods. ANSI E1.4 recommends retaining rigging system documentation for the life of the system.
Records must be readily available for fire marshal inspection, insurance audits, and legal review following incidents.
Maintenance: Preserving System Integrity
Reactive maintenance—fixing problems after they occur—is inadequate for life-safety systems. Preventive maintenance programs address degradation before failures occur.
Routine Maintenance Tasks
Quarterly:
- Lubricate guide tracks and roller assemblies per manufacturer specifications
- Clean guide tracks removing debris and accumulation
- Inspect and lubricate cable sheaves and counterweight arbor per ANSI E1.4
- Verify proper tension in drive cables
- Test limit switches and position indicators
- For powered systems: Verify hoist hour-meter readings and schedule maintenance per ANSI E1.6-1 requirements
Semi-Annually:
- Inspect electrical control panels for loose connections or deterioration
- Test emergency power backup systems
- Verify fire alarm system integration and communication
- Inspect structural support points for cracks, deformation, or deterioration
As Needed:
- Clean fire curtain fabric using manufacturer-approved methods (many flame-retardant treatments are water-soluble and can be destroyed by improper cleaning)
- Replace worn or damaged mechanical components
- Repair fabric tears or damage (repairs must maintain flame resistance certification)
- Replace wire rope when ANSI E1.4 retirement criteria are met
- Service powered hoists per manufacturer and ANSI E1.6-1 requirements
Who performs maintenance: Manufacturer-authorized service technicians or qualified theatrical rigging technicians with documented fire curtain maintenance training and familiarity with ANSI E1 standards. General building maintenance staff lack specialized knowledge required for fire curtain systems.
Wire Rope Retirement and Replacement
ANSI E1.4 establishes specific retirement criteria for wire rope used in entertainment rigging systems, including fire curtain counterweight systems:
Retirement criteria include:
- Six randomly distributed broken wires in one rope lay, or three broken wires in one strand in one rope lay
- Wear exceeding one-third the original diameter of outside wires
- Kinking, crushing, bird-caging, or other distortion
- Heat damage or electric arc damage
- Corrosion
- Reduction of rope diameter exceeding specified tolerances
Fire curtain wire rope requires more conservative retirement criteria than standard counterweight systems due to life-safety function. Consult manufacturer specifications and qualified inspectors for fire curtain-specific retirement recommendations.
Powered Hoist System Maintenance
Fire curtains utilizing powered hoist systems require maintenance per ANSI E1.6-1 and manufacturer specifications:
- Operating hour-based maintenance schedules (many hoists require service every 1,000-2,000 operating hours)
- Brake testing to verify holding capacity meets or exceeds rated load
- Load testing at intervals specified by manufacturer (typically annually or after major repairs)
- Electrical system testing including contactors, limit switches, and control circuits
- Chain or wire rope inspection per applicable standards
Powered hoist maintenance requires specialized training on specific equipment models. Manufacturer-authorized service technicians provide highest assurance of proper maintenance.
Flame Resistance Re-Certification
Flame-retardant treatments degrade over time through:
- UV exposure from stage lighting
- Atmospheric contamination
- Physical wear
- Age-related chemical breakdown
Re-certification intervals depend on treatment type:
- Topical treatments (applied to fabric surface): Typically 3-5 years, or after any cleaning
- Inherent flame resistance (chemically integrated into fabric): Typically 5-10 years
- After repairs or modifications: Immediate re-certification required
Re-certification requires laboratory testing per NFPA 701 with updated certification labels and documentation.
Critical: Operating a fire curtain with expired or uncertain flame resistance certification violates NFPA 701 and creates severe liability exposure. Budget for re-certification as part of routine maintenance costs.
Operational Protocols: Maintaining Readiness
Clearance Requirements
The area surrounding the fire curtain—both upstage and downstage—must remain clear of obstructions:
Prohibited:
- Scenery pieces stored or positioned near proscenium opening
- Lighting fixtures rigging within clearance envelope
- Cables, ropes, or rigging crossing fire curtain travel path
- Equipment stored on stage floor preventing complete seal
- Loading fire curtain rigging system beyond design working load limits (ANSI E1.4 and E1.6-1 violations)
Required clearance: Varies by fire curtain design and manufacturer specifications, typically 18-24 inches minimum from curtain travel path. Verify specific requirements in manufacturer documentation and engineering drawings.
Enforcement: Technical directors and stage managers must maintain awareness of clearance requirements during load-in, rehearsals, and performances. Establish written protocols prohibiting clearance violations.
Emergency Manual Release
Fire curtains must be manually releasable in emergency situations when automatic systems fail or when rapid deployment is required.
Requirements:
- Manual release mechanism must be clearly identified with signage per ANSI E1.4 requirements for counterweight systems
- Release location must be accessible without entering stage area
- Operation must require single, deliberate action (pull handle, release lever) designed to prevent accidental activation
- Signage must be illuminated or photoluminescent for visibility during power failures
- Release mechanism must function reliably under emergency conditions
Training: All technical staff, stage managers, and house managers must know manual release locations and operation procedures. Include manual release operation in regular training programs.
Smoke Pocket Maintenance
Smoke pockets (also called smoke baffles) prevent smoke from traveling over the top of the fire curtain. These are often neglected components despite being NFPA 101 requirements.
Inspection items:
- Fabric integrity (similar to fire curtain requirements)
- Attachment security to building structure or rigging system
- Seal integrity preventing smoke bypass
- Clearance from rigging and lighting systems
- Compliance with ANSI E1 standards if attached to rigging infrastructure
Include smoke pocket inspection in monthly operational testing and annual comprehensive inspections.
Training Programs: Building Competency
Effective fire curtain safety requires differentiated training for distinct roles:
Technical Staff Training (Stage Managers, Technical Directors, Crew Leads)
Content:
- Fire curtain purpose and life-safety function
- Monthly operational testing procedures and documentation
- Basic rigging system inspection per ANSI E1.4 or E1.6-1 (visual inspection, identifying obvious defects)
- Obstruction recognition and clearance maintenance
- Emergency manual release operation
- Deficiency identification and reporting procedures
- Integration with building fire alarm and evacuation systems
- Understanding working load limits and prohibition on overloading
- Wire rope or chain retirement criteria recognition
Frequency: Initial training upon hire, annual refresher training, additional training following fire curtain repairs or modifications
Delivery: Hands-on training by qualified fire curtain inspector, ETCP-certified rigger, or manufacturer representative with expertise in ESTA technical standards
Performers and General Staff Training
Content:
- Fire curtain purpose and appearance
- What fire curtain deployment sounds and looks like
- Evacuation procedures when fire curtain deploys
- Prohibition on obstructing fire curtain, smoke pockets, or rigging systems
Frequency: Initial training, refresher during production safety briefings
Delivery: Can be integrated into general safety orientation programs
Administrative Staff Training
Content:
- Regulatory obligations (NFPA 80, NFPA 101, ANSI E1 standards, local codes)
- Inspection and testing documentation requirements
- Budgeting for inspection, testing, and maintenance
- Fire marshal coordination and compliance verification
- Understanding of ESTA Technical Standards Program and ANSI accreditation process
- Liability implications of non-compliance
Frequency: Initial training upon assuming theater oversight responsibilities, updates when regulations change
Delivery: Professional development through theater associations (USITT, ESTA), insurance providers, or safety consultants
Emergency Procedures: When Systems Activate
Fire Curtain Deployment During Event
Immediate actions:
- Initiate building evacuation per fire emergency action plan
- Notify fire department (automatic via fire alarm system, verify manual notification as backup)
- Account for all personnel (backstage, front of house, technical positions)
- Ensure no one attempts to raise deployed fire curtain or access stage area
- Provide information to responding fire department
Do not:
- Attempt to raise fire curtain until fire department authorizes
- Allow personnel to remain backstage for equipment retrieval
- Assume curtain deployment was false alarm without fire department verification
Post-incident:
- Document circumstances of deployment
- Engage qualified inspector for post-deployment inspection before returning to service, including verification of rigging system integrity per ANSI E1 standards
- Review incident with all personnel identifying lessons learned
- Report incident to insurance carrier
- Coordinate with fire marshal for incident review if required
Unintended Deployment
Accidental fire curtain deployment (mechanical failure, inadvertent activation, control system malfunction) requires:
- Immediate area evacuation as precaution
- Investigation of deployment cause by qualified personnel
- Comprehensive inspection before returning to service, including rigging system and structural support verification
- Correction of underlying cause (may require manufacturer involvement)
- Documentation of incident and corrective actions
- Review of incident with technical staff to prevent recurrence
Administrative Responsibilities: Ensuring Compliance
As theater administrator, you bear ultimate responsibility for fire curtain compliance regardless of delegation to technical staff.
Essential Actions
1. Verify current compliance status
- Locate and review most recent annual inspection report
- Verify monthly testing documentation is current and complete
- Confirm flame resistance certification is valid
- Review fire marshal inspection reports and ensure all deficiencies addressed
- Verify compliance with applicable ANSI E1 standards for rigging or hoist systems
2. Establish written protocols
- Monthly operational testing procedures and documentation forms
- Clearance maintenance protocols
- Emergency manual release operation procedures
- Deficiency reporting and resolution processes
- Training requirements and documentation
- Protocols referencing NFPA and ANSI standards applicable to your fire curtain system
3. Budget appropriately
- Annual qualified inspector fees (ensure inspector credentials include ANSI E1 knowledge)
- Routine maintenance and lubrication
- Flame resistance re-certification testing
- Component replacement reserves (wire rope, hoist service, mechanical parts)
- Training program costs including ESTA-affiliated professional development
- ETCP certification support for technical staff
4. Maintain relationships with qualified service providers
- Identify and pre-qualify fire curtain inspectors and service technicians with ANSI E1 expertise
- Establish service agreements preventing emergency scheduling delays
- Coordinate with fire alarm service providers for integrated system testing
- Maintain contact with manufacturer technical support
5. Coordinate with Authority Having Jurisdiction
- Schedule and facilitate fire marshal inspections
- Provide requested documentation promptly
- Address cited deficiencies within required timeframes
- Maintain occupancy permit compliance
6. Stay current with standards revisions
- Monitor NFPA and ESTA Technical Standards Program for standard updates
- Participate in industry associations (USITT, ESTA) for continuing education
- Subscribe to technical bulletins and interpretation documents
- Budget for compliance upgrades when standards change
Consequences of Non-Compliance
Non-compliance with fire curtain requirements creates multiple liability exposures:
Legal liability: Injuries or deaths resulting from fire curtain failures due to inadequate inspection or maintenance create civil liability. Documented non-compliance with NFPA standards or ANSI E1 standards (when applicable to rigging systems) establishes negligence.
Criminal liability: Gross negligence resulting in death can result in criminal charges against responsible administrators.
Insurance implications: Many theater insurance policies require NFPA compliance and may reference ANSI standards for entertainment equipment. Non-compliance may void coverage, leaving institutions to bear full loss costs.
Regulatory penalties: Fire marshals possess authority to:
- Impose civil penalties for code violations
- Restrict or prohibit building occupancy until compliance achieved
- Revoke certificates of occupancy
- Refer violations for criminal prosecution
Reputational damage: Fire incidents, particularly those resulting in injury, generate significant negative publicity affecting enrollment, donations, and community relationships.
Conclusion
Fire curtain systems represent complex integration of mechanical, electrical, and fire protection technologies requiring specialized expertise for installation, inspection, and maintenance. Generic facility maintenance approaches are inadequate for these life-safety systems.
Your responsibility as administrator extends beyond acknowledging that fire curtains exist. You must ensure:
- Qualified inspectors with knowledge of NFPA and ANSI E1 standards conduct required monthly and annual testing
- Documentation systems capture and retain required records per multiple standard requirements
- Budgets provide adequate resources for inspection, testing, and maintenance by qualified professionals
- Technical staff receive appropriate training including basic understanding of applicable standards
- Clearance protocols prevent obstruction or damage
- Flame resistance certification remains current
- Rigging and hoist systems supporting fire curtains comply with ANSI E1 requirements
- Fire marshal requirements are met consistently
Fire curtains function correctly for decades when properly maintained, or fail catastrophically when neglected. The difference is administrative commitment to systematic, ongoing compliance with established standards from NFPA, ANSI, and manufacturer specifications.
The integration of ESTA Technical Standards Program documents (ANSI E1 standards) with traditional fire protection requirements ensures that fire curtain systems meet both life-safety objectives and entertainment industry best practices for rigging and hoist systems. This comprehensive approach provides maximum safety assurance for theater occupants and personnel.
Resources
NFPA 101: Life Safety Code – Available through NFPA.org, establishes fire curtain requirements for assembly occupancies
NFPA 80: Standard for Fire Doors and Other Opening Protectives – Establishes inspection, testing, and maintenance requirements
NFPA 701: Standard Methods of Fire Tests for Flame Propagation – Governs flame resistance testing and certification
ESTA Technical Standards Program – www.esta.org/tsp – Develops ANSI-accredited standards for entertainment technology including rigging and hoist systems. Provides technical bulletins, interpretation documents, and training resources.
ANSI E1.4: Manual Counterweight Rigging Systems – Available through ESTA or ANSI, establishes requirements for counterweight rigging systems commonly used with fire curtains
ANSI E1.6-1: Powered Hoist Systems – Available through ESTA or ANSI, establishes requirements for powered entertainment hoists used in some fire curtain installations
ANSI E1.43: Performer Flying Systems – Available through ESTA or ANSI, contains relevant provisions for overhead rigging inspection and maintenance
Local Fire Marshal – Contact for jurisdiction-specific requirements, inspection scheduling, and compliance verification
United States Institute for Theatre Technology (USITT) – www.usitt.org – Technical theater safety resources and professional development
Entertainment Technician Certification Program (ETCP) – www.etcp.esta.org – Provides industry-recognized certification for theater riggers demonstrating knowledge of ANSI E1 standards
Fire curtain manufacturer – Provide installation manuals, inspection procedures, authorized service technician lists, and technical support
References
American National Standards Institute. (2016). ANSI E1.43-2016: Entertainment technology—Performer flying systems. ESTA.
American National Standards Institute. (2022a). ANSI E1.4-2022: Entertainment technology—Manual counterweight rigging systems. ESTA.
American National Standards Institute. (2022b). ANSI E1.6-1-2022: Entertainment technology—Powered hoist systems. ESTA.
National Fire Protection Association. (2024). NFPA 13: Standard for the installation of sprinkler systems. NFPA.
National Fire Protection Association. (2024). NFPA 80: Standard for fire doors and other opening protectives. NFPA.
National Fire Protection Association. (2024). NFPA 101: Life safety code. NFPA.
National Fire Protection Association. (2024). NFPA 701: Standard methods of fire tests for flame propagation of textiles and films. NFPA.
Occupational Safety and Health Administration. (29 CFR 1910.38). Emergency action plans. U.S. Department of Labor.