Workplace Safety Blog Post

Rules for Exit Routes – OSHA Standards 1910.36 and 1910.37

exit door with illuminated signAn 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.

Examples of Exit Route Citations

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.

Exit Route – Definition

Floor Sign

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.

Construction and Design Requirements for Exit Routes (1910.36)

construction of exit routesFirst of all, exits must be designed for easy access. Keep the following rules for the construction and design of exit routes in mind:

  • Exit routes must be permanent.
  • There must be enough exit routes. – Usually this means two exits that are far enough from each other that both won’t be blocked by a fire or other hazard. Sometimes one exit is adequate or three or more exits are needed depending on the occupancy of the building.
  • Exits must lead to a street, refuge area, open space or other area with access to the outdoors.
  • Openings to exits must be protected by self-closing fire doors (to ensure those using the exit stay safe).
  • Exit doors must be unlocked so they can be opened from the inside.
  • Any room connected to an exit route must have a side-hinged door that swings outward (if more than 50 people occupy the room).
  • An exit access must be at least 28 inches wide.
  • An exit must be 7.5 feet high.
  • Fire-resistant materials should protect exits – If the exit connects one, two or three stories, these materials should have a one-hour fire-resistance rating. If the exit connects more than three stories, a two-hour resistance rating is required.

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.

Maintenance and Safety Features of Exit Routes (1910.37)

exit sign

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:

  • Flammable furnishings and décor should be kept away from exit routes.
  • Exit routes should be unobstructed.
  • Exit routes should be well lit.
  • Door areas should be kept unobstructed (Consider a door swing floor label)
  • Exit doors shouldn’t be obscured by decorations.
  • Doors that are not exits but are located near exit access points should be labeled “Not an Exit” or labeled with their use (for example, “To Basement” or “Closet”).
  • Signs should be posted directing people to exits.
  • “EXIT” signs must be placed at exits.
  • Routes must be maintained during any construction or repair work that occurs at the workplace.
  • An emergency alarm system must be present and operational.

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.

A Few More Exit Route Tips

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.

floor markings, exit route
Floor tape can be used to illuminate exit routes.

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.




Additional Resources