Emergency Action Plans (EAPs) are required of all employers by federal law. No types of businesses are exempt. So, every camp — no matter its type, size, or location — must create and train its employees on an EAP per OSHA regulations (US Department of Labor, Occupational Safety and Health Administration, 2024).

What is the origin story of EAPs? It starts with what your lawyer calls “duty of care.” I workshop duty of care for lawyers, where, for eight hours, we explore all the details and extensions of duty of care for all kinds of employers.

Let me give you that expensive, eight-hour workshop in a single sentence: Everything is always your fault.

Isn’t duty of care one of those foggy notions consultants use to scare employers?

No.

According to the Occupational Safety and Health Act of 1970, “ . . . each employer shall furnish . . . a place of employment . . . free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees” (Congress.gov, n.d.).

This is not a best practice. Not a guideline. Not a code. Not a regulation. This is federal law passed almost unanimously by the US Senate and US House in 1970.

So, if camp EAPs are required by law, then every workplace must already have one, right?

Well, yes and no. Yes, most camps I visit have some paperwork they call an emergency plan. But is it a real EAP as defined by law? Not really. Most plans I see don’t pay attention to regulations, fire code requirements, and standards issued by many smart, authoritative associations — like the American Camp Association (ACA). Given that emergencies can injure and kill, many government agencies and associations issue an array of standards that dictate how every camp’s EAP shall be written and trained on, including:

• Occupational Safety and Health Administration (OSHA)
• State Fire Code
• Americans with Disabilities Act (ADA)
• National Fire Protection Association (NFPA); dozens of standards revered by courts, including the Supreme Court of the United States
• ACA

While implementing all ACA standards will serve as a giant step forward, camps should also comply with OSHA, the state fire code, NFPA, ADA, and additional standards that might be used against any camp once sued. Together, these standards testify to any camp administration what is required by law in their EAP and associated training.

All-hazards Planning and Training

The NFPA has been writing standards regarding workplace emergency response since 1896. In the 129 years since, this association has promulgated 300 standards, most of which make up all state fire codes and are embedded in OSHA regulations. One of their standards is NFPA 1660, Standard for Emergency, Continuity, and Crisis Management: Preparedness, Response, and Recovery, 2024 Edition. Section 5.2.2.1 requires that every employer shall plan and train for a list of 77 different emergencies, from an active shooter to wildfires.

Three Imperatives

In creating and training employees on camp EAPs, three imperative activities apply to all those very different kinds of emergencies:

The four-minute law. In the great majority of emergencies, the injuries, and worse, will happen very quickly. Research findings on emergency situations — active shooters, fires, medical events, assaults, bullying, hazing, bomb threats, explosions, chemical spills, missing campers, hostage situations, aquatics accidents, child abuse, tornados — reveal that the first four minutes are when the real damage tends to occur. Yet, police, the fire department, and EMTs generally can’t reach you in response to a 911 call in less than 10 minutes. For many camps, emergency response will come after 10 to 40 minutes. In those cases, police, firefighters, and EMTs are the official responders but not the first responders. You, the camp staff, are the first responders. You’re on your own until additional help arrives. Under every state fire code and OSHA regulation, camps shall create an emergency team and train staff in that job description.

Amateurs talk emergencies; professionals talk command, control, and communications (CCC). If camps have robust CCC, they can be successful. Without robust CCC, camps will fail. Who is that one person in command of any emergency? What if that person is not available? Who is in the chain of command? Who are the crisis captains — many middle managers who take command at far-flung activities all over the campgrounds? Who are the searchers? Buddies for mobility-challenged personnel? Who are the individuals trained to guide emergency services to the emergency occurring in every camp area?

Commanders give orders in a four-minute world. Designated camp staff given specific jobs to implement ensure control. Multiple vehicles for communications guarantee everyone can be reached immediately: two-way radios, emergency notification systems to phones via text, email, and calls, public address systems, bullhorns. When it comes to emergency communications to save lives, redundancy is a beautiful thing. Redundancy is a beautiful thing. Redundancy is a beautiful thing.

Great plans are a smart thing. Training is everything. Yes, training staff before camp sessions is in camp directors’ DNA. However, training for emergencies has a detailed, legal definition under OSHA regulations (2024) and ACA accreditation standards:

Camp shall train all employees, full and part-time, from the CEO, owner, and executive director to the volunteers and interns, whether paid or unpaid.

In a classroom.

Annually.

At hire.

Using a “qualified” trainer; qualified by experience, training, or certification on all hazards.

Screen training can supplement the classroom training. However, screen training can never substitute for the annual classroom training.

Robust, in-classroom training of command, control, and communications to prepare for all hazards in a four-minute world, in a classroom where direct verbal interaction between experienced, informed trainers and the trainees occurs is not practiced by many camps. This can result in frequent gaps in some camps’ EAPs.

Gaps

Here are the 17 gaps most often found in camp Emergency Action Plans:

1. Plans don’t recognize the four-minute law. There will be no convening or huddles. Only trained, fast action from the get-go will succeed.
2. Emergency plans fail to address all hazards as defined by national standards.
3. Plans don’t recognize ADA emergency response regulations for mobility-challenged staff, campers, visitors, etc.
4. Planning, training, and practicing for field trip emergencies seldom occurs, and CCC rules are not established.
5. Headcount systems are thin and slow. Accounting for all personnel is required by law. It is also the hardest thing to do in a four-minute world.
6. Senior staff members often provide training, but if they aren’t qualified by training, certification, or experience in all-hazards planning, they probably don’t have the skills needed to do so.
7. The emergency team is often not big enough to respond to all hazards in a four-minute world.
8. A camp’s chain of command is frequently too thin with not enough commanders.
9. Communication methods are inadequate. Not everyone carries two-way radios, all the time, everywhere. The communications plan may not be operational at night, and proper radio use isn’t part of official training
10. Camps don’t utilize a tabletop exercise to make sure everyone was listening during planning and training. This “is an informal, discussion-based session in which a team discusses their roles and responses during an emergency, walking through one or more example scenarios” (Fruhlinger, 2024).
11. A written medical standard of care is missing or too vague. Who is trained to take command of and implement appropriate medical care before EMTs arrive on the scene? Does camp have a First Aid Plan and a Bloodborne Pathogens Plan as required by OSHA regulations? Does camp follow ACA Health and Wellness standards? Are there several AEDs around campus? Is NARCAN available?
12. Fire extinguisher training and use are not OSHA-compliant.
13. Camps have too often cut and pasted other camps’ procedures or taken them from the Internet to create their plans. However, EAPs are required by law to be site-specific.
14. Emergency plans are out of date or incomplete, and they’ve neglected to include responses thought unnecessary to wildfires, flash floods, a knife assault, or other potential emergency situations.
15. Most camps could not survive an inspection today by the fire marshal and an OSHA compliance officer.
16. Camps have been lucky. But luck is not a strategy.
17. No independent assessment of a camp’s emergency plan has been conducted. If we’re smart, we should all get an annual physical from our doctor. Camps should apply that same philosophy to an annual assessment of their EAP by an independent expert.

What’s the Root Cause?

So, why do so many camps suffer from these 17 gaps? Denial. Driven by:

• Ignorance of their duty of care and how camps are required to meet that duty.
• Feeling lucky that no real emergency has occurred — so far.
• The fact that no one has asked about the current emergency plan and training or requested a review of this core management responsibility.

Is the remedy simple?

When I was in Basic Training in the US Army, our drill sergeant — tasked with training us in life-threatening emergencies — pointed out day one: “For every complex problem, there is a simple solution that’s always wrong.”

Nothing about planning and training camp EAPs is simple. But the first step is straightforward: Get an independent assessment of your current plan and training.

Contact your local chapter of the International Association of Emergency Managers (IAEM, 2026) to partner with a workplace Certified Emergency Manager.

Photo courtesy of Camp K on Kenai Lake, Camp Fire Alaska, Cooper Landing, AK

References

National Fire Protection Association. (2024). NFPA 1660: Standard for emergency, continuity, and crisis management: Preparedness, response, and recovery (2024 ed.). Author.

Fruhlinger, J. (2024, April 2). What is a tabletop exercise? CSO. csoonline.com/article/570871/tabletop-exercises-explained-definition-examples-and-objectives.html

International Association of Emergency Managers. (2026) About IAEM. iaem.org/About

US Department of Labor, Occupational Safety and Health Administration. (2024). Occupational safety and health standards (29 C.F.R. Part 1910). US Government Publishing Office. ecfr.gov/current/title-29/part-1910

Bo Mitchell, CEM, CPP, CHS-V, CBCP, CSI-ML, HSEEP, CSSAS, CNTA, IAC, MOAB, CHSP, CHEP, CSHM, CESCO, CHCM, CFC, CSSM, CSC, CAS, TFCT3, CERT, CHSEMR, CMC, was police commissioner of Wilton, Connecticut, for 16 years. He retired to found 911 Consulting, which creates emergency, disaster recovery, business continuity, crisis communications, and pandemic plans, plus training and exercises for organizations like GE, Hyatt, H&R Block, MasterCard, 34 campuses, and 21 summer camps. He serves clients headquartered from Boston to LA working in their facilities from London to San Francisco. Bo has earned 23 certifications in homeland security, emergency management, disaster recovery, business continuity, safety, and security. He also serves as an expert in landmark court cases nationally. He has presented at the ACA National Conference and ACA regional events on multiple occasions.