Exit Routes: Design, Marking, and Upkeep (29 CFR 1910.36 and 1910.37)

In an emergency, people get hurt when the way out is locked, blocked, dark, or hard to find. 29 CFR 1910.36 sets how exit routes must be designed and built, and 1910.37 sets how you must maintain, light, and mark them.

Who it applies to

Sections 1910.34 through 1910.39 apply to workplaces in general industry, except mobile workplaces such as vehicles or vessels (1910.34(a)).

OSHA will deem an employer that demonstrates compliance with the exit-route provisions of NFPA 101, Life Safety Code, 2009 edition, or of the International Fire Code, 2009 edition, to be in compliance with the corresponding requirements in 1910.34, 1910.36, and 1910.37 (1910.35).

Four defined terms matter (1910.34(c)):

Exit route: a continuous and unobstructed path of exit travel from any point within a workplace to a place of safety. It consists of the three parts below.
Exit access: the portion that leads to an exit.
Exit: the portion generally separated from other areas to provide a protected way of travel to the exit discharge.
Exit discharge: the part that leads directly outside or to one of the places listed under "Exit discharge" below.

What the standard requires

Design and construction

Each exit route must be a permanent part of the workplace (1910.36(a)(1)).
Construction materials separating an exit from other parts of the workplace must have a one-hour fire resistance rating if the exit connects three or fewer stories, and two-hour if four or more (1910.36(a)(2)).
An exit may have only the openings necessary for access from occupied areas or to the exit discharge. An opening into an exit must be protected by a self-closing fire door that remains closed, or closes automatically when a fire alarm or employee alarm system sounds. Each fire door, including its frame and hardware, must be listed or approved by a nationally recognized testing laboratory (1910.36(a)(3)).

Number of exit routes

At least two exit routes must be available, except where a single route is permitted (next bullet). They must be located as far away as practical from each other, so that if fire or smoke blocks one, employees can use the second (1910.36(b)(1)).
More than two must be available if the number of employees, the size of the building, its occupancy, or the arrangement of the workplace means all employees would not be able to evacuate safely (1910.36(b)(2)). A single route is permitted where those factors mean all employees would be able to (1910.36(b)(3)).

Exit discharge

Each exit discharge must lead directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside (1910.36(c)(1)). That place must be large enough to accommodate the building occupants likely to use the exit route (1910.36(c)(2)).

Doors

Employees must be able to open an exit route door from the inside at all times without keys, tools, or special knowledge. A device such as a panic bar that locks only from the outside is permitted on exit discharge doors (1910.36(d)(1)).
Exception: 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 you have a plan to remove occupants during an emergency (1910.36(d)(3)).
A side-hinged door must be used to connect any room to an exit route (1910.36(e)(1)). It must swing out in the direction of exit travel if the room is designed to be occupied by more than 50 people or is a high hazard area (1910.36(e)(2)).

Capacity, height, and width

Exit routes must support the maximum permitted occupant load for each floor served (1910.36(f)(1)). Capacity may not decrease in the direction of travel to the exit discharge (1910.36(f)(2)).
The ceiling must be at least 7 feet 6 inches high. Any projection from the ceiling must not reach a point less than 6 feet 8 inches from the floor (1910.36(g)(1)).
An exit access must be at least 28 inches wide at all points. Where only one exit access leads to an exit or exit discharge, the exit and exit discharge must be at least as wide as the exit access (1910.36(g)(2)).
The width of an exit route must also be sufficient to accommodate the maximum permitted occupant load of each floor served by the exit route (1910.36(g)(3)).

Outdoor exit routes

An outdoor exit route is permitted. It must meet the indoor minimum height and width requirements (1910.36(h)) and must:

Have guardrails to protect unenclosed sides if a fall hazard exists (1910.36(h)(1)).
Be covered if snow or ice is likely to accumulate, unless you can demonstrate that any accumulation will be removed before it presents a slipping hazard (1910.36(h)(2)).
Be reasonably straight, with smooth, solid, substantially level walkways (1910.36(h)(3)).
Have no dead end longer than 20 feet (1910.36(h)(4)).

Keeping routes clear and safe

Exit routes must be kept free of explosive or highly flammable furnishings or other decorations (1910.37(a)(1)).
Routes must be arranged so employees will not have to travel toward a high hazard area, unless the path is effectively shielded from it by suitable partitions or other physical barriers (1910.37(a)(2)).
Exit routes must be free and unobstructed. No materials or equipment may be placed within the exit route, permanently or temporarily. Stairs or a ramp must be provided where the route is not substantially level (1910.37(a)(3)).
Safeguards designed to protect employees during an emergency, such as sprinkler systems, alarm systems, fire doors, and exit lighting, must be in proper working order at all times (1910.37(a)(4)).

Lighting and marking

Each exit route must be adequately lighted so that an employee with normal vision can see along it (1910.37(b)(1)).
Each exit must be clearly visible and marked by a sign reading "Exit" (1910.37(b)(2)).
If the direction of travel to the exit or exit discharge is not immediately apparent, signs must be posted along the exit access indicating the direction to the nearest exit and exit discharge (1910.37(b)(4)).
Each doorway or passage along an exit access that could be mistaken for an exit must be marked "Not an Exit" or similar, or have a sign indicating its actual use, such as "Closet" (1910.37(b)(5)).
Each exit sign must be illuminated to a surface value of at least five foot-candles by a reliable light source and be distinctive in color. Self-luminous or electroluminescent signs with a minimum luminance surface value of at least .06 footlamberts are permitted (1910.37(b)(6)).
The word "Exit" must be in plainly legible letters not less than 6 inches high, with principal strokes not less than three-fourths of an inch wide (1910.37(b)(7)).

Paint, construction work, and alarms

Fire retardant paints or solutions must be renewed as often as necessary to maintain their fire retardant properties (1910.37(c)).
During new construction, employees must not occupy a workplace until the required exit routes are completed and ready for use for the portion they occupy (1910.37(d)(1)).
During repairs or alterations, employees must not occupy a workplace unless the required exit routes are available and existing fire protections are maintained, or until alternate fire protection that provides an equivalent level of safety is furnished (1910.37(d)(2)).
Employees must not be exposed to hazards of flammable or explosive substances or equipment used during construction, repairs, or alterations that are beyond the normal permissible conditions in the workplace, or that would impede exiting (1910.37(d)(3)).
You must install and maintain an operable employee alarm system with a distinctive signal to warn employees of fire or other emergencies, unless employees can promptly see or smell a fire or other hazard in time to provide adequate warning to them. The system must comply with 1910.165 (1910.37(e)).

Training

Sections 1910.36 and 1910.37 contain no training requirement.

Written programs and records

Sections 1910.36 and 1910.37 contain no written program or recordkeeping requirement. Where exit route doors are locked from the inside in a mental, penal, or correctional facility, 1910.36(d)(3) requires a plan to remove occupants during an emergency, but the text does not say the plan must be in writing.

Easy-to-miss requirements

Door alarms and devices. Exit route doors must be free of any device or alarm that could restrict emergency use of the exit route if the device or alarm fails (1910.36(d)(2)).
Lockable rooms and dead ends. The exit access must not go through a room that can be locked, such as a bathroom, to reach an exit or exit discharge, and may not lead into a dead-end corridor (1910.37(a)(3)).
Stairs that keep going. Exit stairs that continue beyond the exit discharge level must be interrupted at that level by doors, partitions, or other effective means that clearly indicate the direction of travel to the exit discharge (1910.36(c)(3)).
Things that stick out. Objects that project into the exit route must not reduce its width below the minimum width requirements (1910.36(g)(4)).
Blocked views. Each exit route door must be free of decorations or signs that obscure its visibility (1910.37(b)(3)). The line of sight to an exit sign must clearly be visible at all times (1910.37(b)(4)).

Source

This guide is based on the text of 29 CFR 1910.36 and 29 CFR 1910.37, with coverage and definitions from 29 CFR 1910.34 and the alternate code provision in 29 CFR 1910.35, as published on osha.gov. The regulation itself always controls. States that run their own OSHA-approved State Plans may have additional or stricter rules.

Published by TSG Safety. This page explains the rules in plain English and is not legal advice. Browse all guides.