Subpart EMeans of Egress

• Exit means that portion of an exit route that is generally separated from other areas to provide a protected way of travel to the exit discharge.

• Exit access means that portion of an exit route that leads to an exit.

• Exit discharge means 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.

1910.34(c) Definitions1910.34(c) Definitions

• Exit route* means a continuous and unobstructed path of exit travel from any point within a workplace to a place of safety (including refuge areas). An exit route consists of three parts:

– The exit access;

– The exit; and,

– The exit discharge.

• *Equivalent to the term Means of Egress in the Life Safety Code and most local building and fire codes

1910.34(c) Definitions1910.34(c) Definitions

• An employer who demonstrates compliance

with the exit route provisions of NFPA 101-

2000, the Life Safety Code, will be deemed to

be in compliance with the corresponding

requirements in § § 1910.34, 1910.36, 1910.37

NFPA

1910.35 Compliance with NFPA 1910.35 Compliance with NFPA 101-2000, Life Safety Code101-2000, Life Safety Code

• You requested a written confirmation from the Occupational Safety and Health Administration (OSHA) on whether an employer who meets the National Fire Protection Association (NFPA) 101, Life Safety Code, is considered in compliance with OSHA's Subpart E-Means of Egress standard, 29 CFR 1910.35 through 1910.38.

10/01/1993 - NFPA, Life Safety Code 10/01/1993 - NFPA, Life Safety Code and Means of Egressand Means of Egress

• Employers who meet the requirements of NFPA-101 are considered in compliance with 29 CFR 1910, Subpart E. Employer compliance with revised national consensus standards, such as, NFPA-101, which provide equal or greater employee protection to that provided by an earlier version promulgated into OSHA standards, would be acceptable to OSHA.

10/01/1993 - NFPA, Life Safety Code 10/01/1993 - NFPA, Life Safety Code and Means of Egressand Means of Egress

• (b)(1) At least two exit routes must be available in a workplace to permit prompt evacuation during an emergency:

• The exit routes must be located as far away as practical from each other so that if one exit route is blocked by fire or smoke, employees can evacuate using the second exit route

1910.36(b) The number of exit routes 1910.36(b) The number of exit routes must be adequatemust be adequate

• Buildings maintained to provide free and

unobstructed egress from all parts of the

building at all times when it is occupied.

• No lock or fastening to prevent free escape

from the inside of any building shall be installed

except in mental, penal, or corrective

institutions.

1910.36 (b) Fundamental 1910.36 (b) Fundamental RequirementsRequirements

• The following guidance is offered to clarify 29 CFR 1910.36(b)(4) with respect to the definition of "occupied". The 1985 and 1991 editions of NFPA 101, the Life Safety Code, define a building as being "occupied" when more than 10 persons are in it.

• OSHA will not narrow its scope of coverage of 1910.36 to accommodate NFPA's 1985 and the 1991 definition of "occupied". Such an accommodation would provide a level of protection for employees less than that which is afforded by the 1970 edition.

Standard Interpretations Standard Interpretations 06/29/1994 - Key to open locked exits06/29/1994 - Key to open locked exits

• The use of an electronic device that must be pressed before the panic bar can be activated violates the intent of 29 CFR 1910.36(b)(4). Employers utilizing such a system are cited.

• Employees trying to evacuate a smoke filled room may not be able to locate the electronic device and would be trapped at the exit door.

• Depression of the panic bar must open the exit without any prior action. Relays which signal a security monitor of the occurrence and which do not inhibit exiting are permitted.

03/12/1981 - Security door lock system03/12/1981 - Security door lock system

• Each exit discharge must lead directly outside

or to a street, walkway, refuge area, public way,

or open space with access to the outside

Fabricating shop

Offices Storage

Exit access

Exit

DischargeExit

Discharge

1910.36(c)(1) Exit Discharge1910.36(c)(1) Exit Discharge

• Every required exit, approach thereto, and way of travel from the exit into the street or open space, shall be continuously maintained free of all obstructions or impediments to full instant use in the case of fire or other emergency.

1910.36(d) Maintenance1910.36(d) Maintenance

• A side-hinged door must be used to connect 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

1910.36(e)(1) A side-hinged exit door 1910.36(e)(1) A side-hinged exit door must be usedmust be used

• Exit routes must support the maximum

permitted occupant load for each floor served

See factors for occupant load and capacity in NFPA Life Safety Code - Chapter 7

1910.36(f) The capacity of an exit 1910.36(f) The capacity of an exit route must be adequateroute must be adequate

• The capacity of an exit route may not decrease in the direction of exit route travel to the exit discharge

1910.36(f) The capacity of an exit 1910.36(f) The capacity of an exit route must be adequateroute must be adequate

• The ceiling at least seven feet six inches high • Any projection from the ceiling not lower than

six feet eight inches• An exit access must be at least 28 inches wide

at all points7-½ ft.

6 ft.- 8 in.

1910.36(g) Exit minimum height and 1910.36(g) Exit minimum height and width requirementswidth requirements

• Objects that project into the exit route must not reduce the width of the exit route to less than the minimum width requirements for exit routes

1910.36(g) Exit minimum height and 1910.36(g) Exit minimum height and width requirementswidth requirements

• Exit routes must be kept free of explosive or highly flammable furnishings or other decorations

1910.37(a) The danger to employees 1910.37(a) The danger to employees must be minimizedmust be minimized

• Exit routes free and unobstructed

• No materials or equipment may be placed, within the exit route

• The exit access must not go through a room that can be locked

1910.37(a)(3) The danger to 1910.37(a)(3) The danger to employees must be minimizedemployees must be minimized

• Exit routes adequately lighted

• Clearly visible and marked by a sign reading "Exit"

• Free of decorations or signs that obscure the visibility of the exit route door

1910.37(b) Lighting and marking 1910.37(b) Lighting and marking must be adequate and appropriatemust be adequate and appropriate

• (4)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 of travel to the nearest exit

• Additionally, the line-of-sight to an exit sign must clearly be visible at all times

Way to exit isnot apparent

1910.37(b) Lighting and marking 1910.37(b) Lighting and marking must be adequate and appropriatemust be adequate and appropriate

• (5)Each doorway or passage along an exit access that could be mistaken for an exit must be marked "Not an Exit" or similar designation, or be identified by a sign indicating its actual use (e.g., closet)

1910.37(b) Lighting and marking 1910.37(b) Lighting and marking must be adequate and appropriatemust be adequate and appropriate

• (6) Each exit sign must

be illuminated to a

surface value of at

least five foot-candles

(54 lux) by a reliable

light source and be

distinctive in color(7) The word "Exit" in plainly legible letters

not less than six inches

Letters 3/4 inch thick

1910.37(b) Lighting and marking 1910.37(b) Lighting and marking must be adequate and appropriatemust be adequate and appropriate

• (1) Employees must not occupy a workplace until the exit routes required by this subpart are completed and ready for employee use for the portion of the workplace they occupy

1910.37(d) Exit routes must be 1910.37(d) Exit routes must be maintained during construction, maintained during construction,

repairs, or alterationsrepairs, or alterations

• (3) 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 the workplace

1910.37(d) Exit routes must be 1910.37(d) Exit routes must be maintained during construction, maintained during construction,

repairs, or alterationsrepairs, or alterations

• (b) An emergency action plan must be in writing, kept in the workplace, and available to employees

• However, an employer with 10 or fewer employees may communicate the plan orally to employees

1910.38 Emergency action plans 1910.38 Emergency action plans (EAP)(EAP)

• (1) Procedures for reporting a fire or other emergency

• (2) Procedures for emergency evacuation, including type of evacuation and exit route assignments

1910.38(c) Minimum elements of an 1910.38(c) Minimum elements of an emergency action planemergency action plan

1910.38(c) Minimum elements of 1910.38(c) Minimum elements of an emergency action planan emergency action plan

• (3) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate

• (4) Procedures to account for all employees after evacuation

• (5) Procedures to be followed by employees

performing rescue or medical duties

1910.38(c) Minimum elements of an 1910.38(c) Minimum elements of an emergency action planemergency action plan

• (6) The name or job title of every employee who

may be contacted by employees who need

more information about the plan or an

explanation of their duties under the plan

Contacts________ ________ ________

1910.38(c) Minimum elements of an 1910.38(c) Minimum elements of an emergency action planemergency action plan

• An employer must have and maintain an employee alarm system

• The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in § 1910.165

1910.38(d) Employee alarm system1910.38(d) Employee alarm system

• The complexity and sophistication of the alarm system depends on the number and size of operations and the associated degree of hazard for a given facility.

• A small, single-process plant may only require a simple siren to call for evacuations.

• In a larger more complex facility, where multiple contingent responses or multiple contingent evacuation routes may be required of employees, the alarm system should convey clearly the information necessary to allow employees to respond or evacuate.

12/16/1992 - Alarm systems for employee 12/16/1992 - Alarm systems for employee evacuation and/or responseevacuation and/or response

• An employer must designate and train

employees to assist in a safe and orderly

evacuation of other employees

EAP

1910.38(e) Training1910.38(e) Training

• An employer must review the emergency action plan with each employee covered by the plan:– When the plan is developed or the employee is

assigned initially to a job– When the employee's responsibilities under the

plan change; and– When the plan

is changed EAPChange

1910.38(f) Review of emergency 1910.38(f) Review of emergency action planaction plan

• Must be in writing,

• Be kept in the workplace, and

• Be made available to employees for review

• Employer with 10 or fewer employees may communicate the plan orally to employees

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1910.39(b) Written and oral fire 1910.39(b) Written and oral fire prevention plansprevention plans

• A fire prevention plan must include:– A list of all major fire hazards

– proper handling and storage procedures for hazardous materials

– potential ignition sources and their control

– type of fire protection equipment necessary

1910.39(c)(1) Minimum elements of a 1910.39(c)(1) Minimum elements of a fire prevention planfire prevention plan

• (2) Procedures to control accumulations of

flammable and combustible waste materials

Cans of paint left open,not stored or disposed of upon completion ofwork

1910.39(c) Minimum elements of a 1910.39(c) Minimum elements of a fire prevention planfire prevention plan

• (3) Procedures for

regular maintenance of

safeguards installed on

heat-producing

equipment to prevent

the accidental ignition of

combustible materials

1910.39(c)(1) Minimum elements of a 1910.39(c)(1) Minimum elements of a fire prevention planfire prevention plan

• (4) The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires

• (5) The name or job title of employees responsible for the control of fuel source hazards

1910.39(c)(1) Minimum elements of a 1910.39(c)(1) Minimum elements of a fire prevention planfire prevention plan