Emergency preparedness plan

Definition

An emergency preparedness plan is a farm’s written plan for keeping people safe, caring for animals, protecting milk and limiting environmental damage when something goes badly wrong. Customer welfare audits usually require one. OSHA’s emergency action plan rule (29 CFR 1910.38) is a general-industry standard that generally does not cover the farm side of a dairy (see the table below). The EPA spill rule applies to farms storing enough oil or fuel.

Scenarios a dairy plan should cover:

Power loss: standby generator sized for milking, milk cooling, water pumps, ventilation and cooling fans, and feed mixing; fuel on hand; a transfer procedure staff can follow.
Fire: in barns, the parlor, hay or straw storage, or shops.
Flood and severe weather: storms, high wind, snow load, extreme cold, wildfire smoke.
Heat events: cooling failure during high heat (see heat stress and THI).
Chemical, fuel or manure spills: lagoon breach, fuel tank leak, chemical spill in the milk room.
Animal disease events: a reportable or foreign animal disease, stop movement orders (see biosecurity plan).
Milk not picked up: road closures or plant outage; how long the tanks hold, and the approved way to dispose of milk if needed (see Grade A PMO).
Serious worker injury and livestock-trailer accidents.

Each scenario lists who does what, the contacts (911 and the farm’s 911 address and directions, vet, processor, milk hauler, power utility, generator service, state animal health official, environmental agency), where shut-offs are (power, gas, water, chemical), evacuation routes and assembly points for people, and how animals will be fed, watered and, if needed, moved.

Requirements change; confirm the current rules with the regulator or the auditing body. This page is reference material, not legal advice.

How to pull it in DC305

The plan is not in DC305. It lives in the farm’s SOP records, with a copy posted where people work (office, parlor, shop).

DC305 matters for emergencies in two ways:

Paper backup of critical lists. If computers or power are down, staff still need to know which cows are on milk or meat withdrawal, which are in the hospital pen, and which are due to calve. Print these lists regularly. Item names vary by herd; see the herd’s private dc305-vocab mapping and withdrawal times.
```
LIST ID PEN LACT DIM FOR [withhold item]>[today]     cows on withdrawal (item varies by herd)
LIST ID PEN DCC DUE FOR DCC>0                        pregnant animals (milking and dry), with due date
```
Off-site backups of the herd file, so records survive a fire or flood (see DC305 backup files).

DCC>0 (days carrying calf) selects pregnant animals whether they are RC 5 (pregnant) or RC 6 (dry).

Typical range

Herd context: US dairies, freestall or dry-lot; requirements as of current OSHA and EPA rules and typical customer audit standards.

Item	Typical requirement or guideline
OSHA emergency action plan	Generally not a federal requirement for farm operations (see below); where it applies, written, or oral if 10 or fewer employees
OSHA small-farm limit	No OSHA enforcement on farms with 10 or fewer employees (family not counted) and no temporary labor camp in the last 12 months
EPA SPCC plan, farms	2,500 gal or less aggregate aboveground oil: not covered. Over 2,500 up to 6,000 gal with no reportable discharge: temporarily exempt. Over 6,000 gal, or over 2,500 gal with a reportable discharge: plan required
Plan review	At least annually, and after any emergency (common practice)
Drills or walk-throughs	At least annually with staff (common practice)
Generator testing	Run under load on a regular schedule, often monthly (common practice)
Contact list	Posted, current, in the crew’s languages

As of November 2026 (eCFR; OSHA; EPA):

OSHA. 29 CFR 1910.38 applies only when another Part 1910 standard requires an emergency action plan. Part 1910 subparts B–T, which include 1910.38, do not cover agricultural operations (29 CFR 1928.21(b)), and OSHA treats dairy farms as agricultural operations. Non-farm activities on the site (e.g. on-farm processing) can fall under general industry, and state-plan states may set their own rules. Small farms are also protected by the annual appropriations rider above.
EPA SPCC. The general SPCC trigger is more than 1,320 gal of aggregate aboveground oil storage (containers of 55 gal or more). The 2014 WRRDA amendments (Section 1049) raised it for farms to the tiers in the table. EPA still plans a rule to set the final farm threshold between 2,500 and 6,000 gal. Farms with more than 6,000 gal but under 20,000 gal, no tank over 10,000 gal and no reportable discharge history can self-certify their plan; larger farms need a Professional Engineer-certified plan.

Common mistakes

A generator that won’t carry the load. Sized for the parlor only, not milk cooling, water and fans at the same time, or never tested under load.
No 911 address. Rural sites without a clear address or directions for emergency services.
Plan only in English or only in the office.
No paper copy of withdrawal and hospital lists, so treated milk is shipped during an outage.
Contact lists out of date: former managers, wrong vet numbers.
No plan for milk that can’t be shipped, leading to unapproved dumping into waterways or lagoons without notifying the regulator or buyer.
No off-site backup of herd records.