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OSHA and Exits

More Than Just Doors: Do You Know Your Exit Routes?

Providing a compliant emergency exit comprises more than installing a panic bar on an outward opening door and placing an exit sign above it. OSHA, in fact, favors the term exit route, which consists of three parts.

  • The exit access—the portion of the exit route that leads to the exit;

  • The exit itself—the portion of the exit route that provides a protected way to the exit discharge; and

  • The exit discharge—the part of the exit route that leads directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside.e

OSHA regulations generally require that a workplace have at least two exit routes, but the number may be different based on various factors. For example, more than two exit routes are required if two exit routes would not allow safe evacuation based on the number of employees, size of the building, or arrangement of the workplace. On the other hand, one exit route is permissible “where the number of employees, the size of the building, its occupancy, or the arrangement of the workplace is such that all employees would be able to evacuate safely during an emergency” (29 CFR 1910.36(b)(3)). OSHA attempts to firm up this somewhat subjective requirement by referring employers to guidance in National Fire Protection Association (NFPA) 101-2009, Life Safety Code, or International Fire Code (IFC)-2009.

Side-Hinged Doors, Dimensions, and More

OSHA’s complete design and construction regulations for exit routes are at 29 CFR 1910.36. Following are some of the key requirements:

  • Exit discharge leads must be large enough to accommodate the building occupants likely to use the exit route.

  • Exit stairs that continue beyond the level on which the exit discharge is located must be interrupted at that level by doors, partitions, or other effective means that clearly indicate the direction of travel leading to the exit discharge.

  • An exit door must be unlocked. Employees must be able to open an exit route door from the inside at all times without keys, tools, or special knowledge. A panic bar or similar device that locks only from the outside is permitted on exit discharge doors. An exit route door may be locked from the inside only in mental, penal, or correctional facilities and then only if supervisory personnel are continuously on duty and the employer has a plan to remove occupants from the facility during an emergency.

  • The exit door must be side-hinged. Also, a side-hinged door must be used to connect any room to an exit route.

  • The door that connects any room to an exit route must swing out in the direction of exit travel if the room is designed to be occupied by more than 50 people or if the room is a high-hazard area (i.e., contains contents that are likely to burn with extreme rapidity or explode).

  • An exit route must meet minimum height and width requirements. Ceilings of exit routes must be at least 7 feet, 6 inches (in.) high. An exit access must be at least 28 in. wide at all points. Where there is only one exit access leading to an exit or exit discharge, the width of the exit and exit discharge must be at least equal to the width of the exit access. Objects that project into the exit must not reduce its width.

  • An exit must be separated by fire-resistant materials. Construction materials used to separate an exit from other parts of the workplace must have a 1-hour fire-resistance rating if the exit connects three or fewer stories and a 2-hour fire-resistance rating if the exit connects four or more stories.

Emergency Action Plans

Also, procedures for emergency evacuation, including type of evacuation and exit route assignments, must be part of emergency action plans ((EAPs), 29 CFR 1910.38(c)(2)) that are required under seven OSHA standards:

  • Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119

  • Fixed Extinguishing Systems, General, 29 CFR 1910.160

  • Fire Detection Systems, 29 CFR 1910.164

  • Grain Handling, 29 CFR 1910.272

  • Ethylene Oxide, 29 CFR 1910.1047

  • Methylenedianiline, 29 CFR 1910.1050

  • 1,3-Butadiene, 29 CFR 1910.1051

Under these standards, any employer with 10 or fewer employees may communicate the plan orally to employees. Employers with more than 10 employees must have written plans that are kept in the workplace and are available for employee review. Notwithstanding these standards, OSHA says it “strongly recommends” that all employers have an EAP.

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