Read the Economic Impact Study of the Ontario Veterinary College at the University of Guelph (pdf)An exit route might seem like one of the simplest parts of a workplace. Just look for the exit sign and head for the door, right? In theory that may be true, but technically speaking, exit routes must have specific features and meet detailed OSHA requirements. OSHA has begun focusing more attention on emergency exit route compliance in recent years, as seen in a memo to the agency’s personnel. Workplace fires in other countries where employees were killed because they couldn’t escape a building have made the news, and OSHA’s director of enforcement programs called specific attention to a fire and explosion at a poultry processing plant in China where over 100 workers died because exits were locked or obstructed. U.S. authorities want to prevent those types of accidents in this country. The types of citations OSHA issues related to exit routes can usually be fixed by simple changes, but in many cases those changes are overlooked.
In 2010, for example, the Home Goods retail chain was fined over $200,000 for repeatedly not complying with regulations for exit routes. At a store in New York, inspectors found the exit routes were blocked by merchandise and equipment, one route was too narrow and an exit sign was missing. A similar citation was issued to Big Lots Stores Inc. in New York in 2013 because merchandise and pallets blocked exit routes. The store also failed to label exit routes and mark doors that could have been mistaken for exits. OSHA issued another serious citation to Gateway Cold Storage in Illinois when inspectors found that exit doors in a food warehouse could not be opened from the inside. The company also didn’t keep exit routes clear of obstacles or maintain working exit lighting. In these cases no one was injured, but had an emergency occurred the employees at these companies could have been in serious danger. Consequently, it’s important to maintain proper exit routes in workplaces in all industries to avoid fines and to keep workers safe.
OSHA defines an exit route as “a continuous and unobstructed path of exit travel from any point within a workplace to a place of safety.” An exit route consists of exit access (the space that leads to an exit), the exit itself (which is separated from other areas so it protects people using the exit) and the exit discharge (which leads to the street, open space or a refuge area). Exit routes are sometimes referred to as “means of egress” and are covered under OSHA standards 1910.36 (“Design and construction requirements for exit routes”) and 1910.37 (“Maintenance, safeguards, and operational features for exit routes). While employers and safety managers will want to consult the regulations to make sure their facilities are completely compliant, the following lists of general rules of exit routes will help explain the basics. Many workplaces may already follow these requirements, especially those related to construction, but let’s take a brief look at construction requirements for exit routes.
Then we’ll take a look at maintenance and safety features of exit routes that are necessary to achieve compliance. First of all, exits must be designed for easy access. Keep the following rules for the construction and design of exit routes in mind: Employers who own buildings must ensure these construction and design requirements are met. Employers who rent space in commercial buildings are still required to maintain a work environment with proper exit routes, though, and they should consult with building owners to make structural changes if necessary. Once proper exits are in place, it’s easy to think nothing else needs to be done to stay OSHA compliant. Like most parts of a workplace, however, exit routes require proper maintenance. They also need to have certain safety features. The following rules apply to exit routes: Keep in mind that OSHA frequently issues citations for exit route problems that fall under the construction category of rules and the maintenance/safety features category, so employers should understand both sections of the regulations.
To help workplaces understand exit route requirements, OSHA offers an eTool for Evacuation Plans and Procedures. The organization’s Exit Route Demonstrations are particularly useful because they provide visuals of various types of violations so users can test their knowledge of exit route requirements. NFPA guidelines for exit routes (NFPA 101 – Life Safety Code) also offer useful information that employers can consider. For example, the organization explains what types of illumination are acceptable for exit signs: external illumination sources, internal illumination and photo luminescent signs. OSHA considered NFPA requirements when designing its regulations, so those who follow NFPA guidelines will be in compliance with OSHA. Employers and safety managers can also consider whether signs and labels marking exit routes will help increase the safety of the facility and keep the workplace OSHA compliant. When an exit isn’t easily visible from a particular location, adding a simple sign with a directional arrow can clear up confusion.
Finally, glow-in-the-dark floor tape placed along exit routes can help employees find their way out during a power outage. Learn about other ways to use visual signs, labels and floor tapes to enhance workplace safety in our podcast.(a) A building to be used as living quarters in a seasonal farm labor camp shall comply with the following requirements: (1) Exits provided shall be safe, adequate, reliable, accessible and unobstructed. Locks or other devices which prevent egress are not permitted. (2) A fire extinguisher with a minimum 10-B rating, consistent with 34 Pa. Code Chapters 49—59, shall be installed and properly maintained in each kitchen area. (3) A fire extinguisher with a minimum 2-A rating, consistent with 34 Pa. Code Chapters 49—59, shall be installed and properly maintained: (i) At a convenient location in each dormitory room. (ii) At a central and convenient location for each group of private or shared sleeping rooms.
(iii) For each 3,000 square feet of floor area or fraction thereof not otherwise covered under subparagraph (i) or (ii). There shall be at least one fire extinguisher per floor, including the basement. (4) In a building of wood frame construction only the first and second floors may be occupied or used. The third floor and above shall be effectively secured to prevent entrance. (5) If a stove, or other device which uses liquid or solid fuel or electricity for heating or cooking, is closer than 36 inches to a wall, the wall shall be covered with fireproof sheeting of at least 6 inches greater in each direction than the stove or heating device. Units tested and approved by the American Gas Association, or Underwriters Laboratories, Inc. may be installed closer than 36 inches without fireproof sheeting if installed according to the manufacturer’s specifications. (6) Stovepipes shall be insulated with fireproof material where they pass through walls, ceilings or floors.
(7) Fuel lines shall be located and protected to prevent accidental breakage. (8) When liquified petroleum gas is used, the storage vessel shall be located outside the building. The vessel shall be securely but not permanently fastened to prevent accidental overturning. A shutoff valve outside of the building shall be provided. Storage vessels for liquified petroleum gas may not be stored under or adjacent to fire escapes or outside stairs. (9) Flammable or volatile liquid or materials may not be stored in or adjacent to rooms used for living purposes except for those needed for current household use. (b) A building subject to the Fire and Panic Act and 34 Pa. Code Chapters 49—59 shall comply with the following requirements in addition to the requirements in subsection (a): (1) The building shall have an occupancy permit issued by the Department of Labor and Industry under the Fire and Panic Act. The building shall obtain the occupancy permit by January 29, 1996.
(2) A minimum of two exits from each floor shall be provided. In situations where regulations adopted under the Fire and Panic Act require two exits per floor, neither of the exits may be a window. When 34 Pa. Code Chapters 49—59 require only one exit per floor, a window may act as the second exit. If a window is to act as the second exit under this provision, the following requirements shall be met: (i) Ground floor windows shall be readily accessible with an openable space of at least 24 inches on each side and not more than 6 feet from the exterior ground. (ii) Windows above the ground floor shall be readily accessible with an openable space of 24 inches on each side, shall be within 3 feet of the floor and, if over 6 feet from the exterior ground, shall have approved outside stairs or an approved fire escape to the ground. The stairs or fire escape shall meet the requirements of subsection (c)(7). (3) A building constructed after January 2, 1981, shall conform with the following.
The building shall be: (i) A one-story construction unless otherwise approved by the Department. (ii) Protected by 1-hour rated construction. A 1-hour rate construction resists the penetration and effects of fire for 1 hour. (c) Occupied buildings within cities of the first class, second class and second class A, which are not subject to the requirements of the Fire and Panic Act and 34 Pa. Code Chapters 49—59, except buildings subject to subsection (d), shall comply with the following requirements in addition to the requirements in subsection (a): (1) In buildings of one-story construction housing eight or fewer persons, two means of egress shall be provided. One of the two means of egress may be a readily accessible window with an openable space of at least 24 inches on each side and which is not more than 6 feet from the exterior ground. (2) Sleeping quarters intended for use by nine or more persons, central dining facilities and common assembly rooms shall have at least two doors remotely separated to provide alternate means of egress to the outside or to an interior hall leading to safe and open space at ground level.
(3) Where flights of stairs serve more than two occupied floors in a building, there shall be a self-closing door at both the lower and upper end of each flight of stairs between two floors, and the stairwell door shall swing in the direction of exit travel. A landing shall be provided beyond each door opening and shall have a width and depth not less than the width of the stairs. The flight of stairs shall be enclosed within smoke-tight walls. (4) At least two safe means of egress to the exterior ground located at opposite sides or ends of the structure shall be provided where persons occupy the second floor. If one means of egress from the second floor is a window, it shall have an openable space of at least 24 inches on each side, shall be within 3 feet of the floor and, if over 6 feet from the exterior ground, shall have approved outside stairs or an approved fire escape to the exterior ground. The outside stair or fire escape shall have a landing at the window. The landing may be no more than 8 inches below the window sill.
The stairs or fire escape shall meet the requirements of paragraph (7). (5) If nine or more persons occupy the second floor, both means of egress shall be a standard stairway with a landing and handrails. (6) At least two safe means of egress to the exterior ground located at opposite sides or ends of the structure shall be provided where persons occupy the third floor. The method of egress shall be outside stairs or fire escapes meeting the requirements of paragraph (7). (7) Outside stairs and fire escapes shall be constructed of metal or fire-retardant or pressure treated wood and shall have at least a 3-foot landing equipped with safety rails immediately under the door or window used as an emergency or fire exit. The stairs or fire escape shall be adequately maintained in a safe condition. (8) Each suite of rooms, consisting of sanitation facilities and cooking facilities, if present, and common living areas, shall have a minimum of one single-station smoke detector which shall be listed by Underwriters Laboratories, Inc. and maintained in proper working order.
The smoke detector shall be installed between the sleeping areas and the path of exit. (9) Buildings constructed after January 2, 1981, shall conform with the following requirements. A 1-hour rated construction resists the penetration and effects of fire for 1 hour. (d) A building which is used for group habitation in which living units or apartments are not mixed vertically and in which three or fewer nonfamily members reside, which is not subject to the Fire and Panic Act or 34 Pa. Code Chapters 49—59, shall comply with the following requirements in addition to those requirements in subsection (a): (1) In single family residences of one-story construction, two means of egress shall be provided. One of the two required means of egress may be a readily accessible window with an openable space of at least 24 inches on each side, and not more than 6 feet from the exterior ground. (2) At least two safe means of egress to the exterior ground located at opposite sides or ends of the structure shall be provided where persons occupy the second floor.
If one means of egress from the second floor is a window, it shall have an openable space of at least 24 inches on each side and shall be within 3 feet of the floor. (3) Each suite of rooms, consisting of sanitation facilities and cooking facilities, if present, and common living areas, shall have a minimum of one single-station smoke detector which shall be listed by Underwriters Laboratories, Inc. and maintained in proper working order. The provisions of this § 82.17 issued under sections 301 and 603 of the Seasonal Farm Labor Act (43 P. S. § § 1301.301 and 1301.603); amended under section 9 of the act of May 18, 1937 (P. L. 654, No. 174) (43 P. S. § 25-9); the Reorganization Plan of 1955 (71 P. S. § 751-12); and sections 1907-A, 1919-A and 1920-A of The Administrative Code of 1929 (71 P. S. § 510-7, 510-19 and 510-20). The provisions of this § 82.17 adopted September 28, 1973, effective September 29, 1973, 3 Pa.B. amended January 2, 1981, effective January 3, 1981, 11 Pa.B.