Back to Basics: Emergency Exits and Keeping the Way Out Clear

Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine emergency exits and OSHA’s requirements for exit routes, doors, and other procedures.

During a fire or another emergency, your employees need a clear exit route and clearly marked and unlocked exit doors.

Your employees’ exit route must remain unobstructed by equipment or stored items, and employees must be able to exit the workplace through doors that are unlocked from the inside.

In one of the most notorious workplace tragedies, workspace obstructions and locked exit doors cost workers their lives. On March 25, 1911, in lower Manhattan’s Greenwich Village, 146 factory workers died in the Triangle Shirtwaist Factory fire.

Fire quickly spread on the 8th, 9th, and 10th floors of the Asch Building, and long worktables and bulky machines hindered many workers’ escape. The factory doors were locked by managers to prevent thefts, trapping the workers, primarily young women who had recently emigrated from Europe, inside. The building’s sole fire escape collapsed during rescue efforts.

America’s oldest professional safety organization, the American Society of Safety Engineers (now the American Society of Safety Professionals (ASSP)) was founded 6 months after the Triangle fire. The fire also spurred the growth of the International Ladies’ Garment Workers’ Union (ILGWU), which merged with several other unions in 2009 to form Workers United, an affiliate of the Service Employees International Union (SEIU).

Exits doors and exit routes, often referred to as “means of egress,” are some of the most fundamental worker safety protections in this country. OSHA’s standards for exit routes and exit doors are unambiguous, and the agency vigorously enforces its rules.

What OSHA regulations require

You can find OSHA’s general industry exit route and exit door regulations in 29 Code of Federal Regulations (CFR) §§1910.34, 1910.35, 1910.36, and 1910.37. The remainder of Part 1910, Subpart E deals with emergency action plans and fire prevention plans. Some of the requirements for emergency action plans include procedures for reporting fires and other emergencies, an alarm system to alert employees, evacuation procedures, accounting for all employees after evacuation, and designating someone to be responsible for the emergency action plan.

The agency does recognize two industry consensus standards as alternatives to its emergency exit regulations. Compliance with the exit route provisions of the 2009 National Fire Protection Association (NFPA) 101 Life Safety Code or the exit route provisions of the 2009 International Fire Code is considered compliance with the OSHA regulations.

OSHA regulations require most workplaces to have at least two designated exit routes. You may need to establish and maintain additional routes if you have a large building or a space configured in a way that could interfere with the safe exit of all employees, customers, and visitors during an emergency.

Exit pathways must be at least 28 inches (in.) wide, and the ceilings along exit routes must be at least 7 feet (ft), 6 in. high. Exit doors must be unlocked from the inside, and

exit routes must:

• Remain free of explosive or highly flammable furnishings and other decorations.
• Be separated by fire-resistant materials and fire-retardant paints or solutions along the exit access, and materials, paint, or solutions must be renewed often enough to maintain their fire-retardant properties.
• Be maintained during any building alteration or renovation, construction, or repairs.
• Be arranged so that employees do not have to travel toward a high-hazard area, unless the path of travel is effectively shielded from the high-hazard area.
• Be unobstructed by materials, equipment, locked doors, or dead-end corridors.
• Have adequate lighting for employees with normal vision.

If the direction of the exit route and doors is not immediately apparent, signs must be posted indicating the necessary direction of travel. Doors along the exit route that could be mistaken for exit doors must be marked “Not an Exit” or with a sign identifying their use, such as “Closet.”

Moreover, exit doors must be free of decorations or signs that would obscure the visibility of the doors. In other words, you must ensure that no draperies or decorative hangings could obstruct the view of or access to the exit route. Ensure that mirrors are not placed in or adjacent to an exit route that could create confusion about the direction of the exit path. Exit doors also must not be decorated in any way that would obscure or confuse the purpose of the doors.

OSHA enforcement

OSHA inspections will include a check of the means of egress in your facility. The agency has cited many retailers, including Dollar General, Dollar Tree and Family Dollar, Target, and T.J.Maxx­, for violations.

In 2020, OSHA reached an agreement with Target Corporation to settle several cases before the Occupational Safety and Health Review Commission. Target agreed to pay $464,750 in penalties to resolve a series of eight cases at the review commission. The agency had issued citations for violations that included blocked or obstructed access to emergency exits and fire exit routes.

The company also agreed to correct exit access and other hazards at about 200 of its stores in Connecticut, Massachusetts, New Jersey, and New York, as well as agreed to unannounced third-party audits to allow auditors to ensure pathways leading to exits are at least 28 in. wide at all points. Additionally, the company agreed to establish anonymous employee complaint reporting via a telephone hotline and/or online so employees can submit safety- and egress-related complaints.

More recent OSHA citations have included:

• OSHA’s citation of TJX Companies, Inc., for repeat and serious violations at a Pooler, Georgia, T.J.Maxx store that included obstructed exit routes.
• On March 13, OSHA announced over $1 million in new penalties for Dollar General for violations that included blocked exit routes and locked exit doors at stores in Florida and Georgia.
• In February, the agency announced a $395,717 penalty for violations at a West Lafayette, Ohio, Dollar General store that included exit routes blocked with wheeled carts, boxes, and bins.
• The agency recently reported having issued more than $15 million in fines for willful, repeat, and serious workplace safety violations at Dollar General Stores since 2017. OSHA also placed Dollar General in its severe violator enforcement program (SVEP).
• OSHA issued $254,478 in fines to Dollar Tree Inc. for three repeat violations at its Mount Pleasant, Texas, store that included merchandise blocking exits and walkways. According to OSHA, inspectors have identified more than 300 violations since 2017 in more than 500 inspections at Dollar Tree and Family Dollar stores operated by Dollar Tree Inc. 

However, exit door and exit route violations occur beyond the retail trade. In 2020, the review commission upheld OSHA’s citation of Timberline Hardwood Floors LLC for violations at its Fulton, New York, plant that included an emergency exit without an illuminated exit sign and a door locked with a deadbolt. In his decision, the administrative law judge concluded that the employer demonstrated plain indifference toward worker safety and health.

In 2019, OSHA cited a Long Island, New York, manufacturer for nine serious and four repeat safety and health violations. Inspectors found that the door to a designated fire exit was jammed and could not be opened. Agency inspectors cited the manufacturer for a repeat violation—failing to ensure employees can open an exit door without keys, tools, or special knowledge. Proposed penalties for the 13 violations totaled $287,212.

Last summer, OSHA’s Region 3 office in Philadelphia launched a 5-year regional emphasis program (REP) for warehousing, storage, and distribution. Inspection procedures for the REP include checks of hazards associated with means of egress regulations (§1910.34, 1910.35, 1910.36, and 1910.37).

The REP focuses on employers in Delaware, the District of Columbia, Pennsylvania, and West Virginia and runs through August 3, 2027, unless extended.

Exit route, exit door checklist

A checklist based on a National Institute for Occupational Safety and Health (NIOSH) list developed for schools may help with your exit compliance:

• Are exits provided to allow building occupants to escape a fire or another emergency?
• Is every exit route and exit to the street maintained free of any obstructions or impediments?
• Are exits maintained to provide a free and unobstructed escape when the room is occupied?
• Are exit doors free of any locks, chains, or fastenings?
• Does every building or area have at least two exits in the event one exit becomes blocked by fire, smoke, or another emergency?
• Do exit doors discharge directly onto a street, a yard, a court, or another open space?
• Do exit doors swing in the direction of travel when an area is occupied by more than 50 people or where hazardous operations are conducted?
• Are all exit routes and exit doors at least 28 in. wide?
• Are exit routes designed and maintained to provide adequate headroom, with the ceiling height at least 7 1/2 ft and any projection from the ceiling more than 6 ft, 8 in. from the floor?
• Is every exit clearly visible and the route to it obvious so everyone readily knows the direction of escape from any point?
• Do all exit paths have adequate and reliable illumination?
• Are exits prohibited in bathrooms or other rooms that could be locked?
• Is the storage of flammable or combustible materials in exit corridors prohibited?
• Is the use of highly flammable furnishings or decorations along exit routes prohibited?
• Is the exit route marked by readily visible signs and arrows when the way to reach it is not immediately visible?
• Are doors, passageways, or stairways that are neither exits nor a way to an exit and that can be mistaken for an exit marked with a sign reading “Not An Exit” or a similar designation (“Basement,” “Storeroom,” “Linen Closet,” etc.)?
• Are exit signs clearly visible, distinctive in color, and easily distinguished from decorations, interior finish, and other signs?
• Is every exit sign illuminated by a reliable light source?
• In areas where lower illumination is permitted, are exit signs internally illuminated?
• Does every exit sign have the word “Exit” in plainly legible letters not less than 6 in. high, with the principal strokes of letters not less than three-fourths of an inch wide?

You can avoid a tragedy like New York’s Triangle Shirtwaist Factory fire by establishing and maintaining two exit routes out of the workplace, keeping exit routes free from obstruction, clearly marking exit doors, and ensuring they remain unlocked from the inside. In the event of a fire or another emergency, your employees’ lives literally depend on it.