Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine workplace fire preparedness.
Have you considered what might happen if a fire broke out in your facility?
On March 25, 1911, 146 garment workers were killed in the Triangle Shirtwaist Factory fire—the greatest workplace disaster in New York City until September 11, 2001.
The fire quickly spread on the building’s 8th, 9th, and 10th floors, and long worktables and bulky machines hindered many workers’ escape. The factory doors were locked to prevent theft and block labor organizers’ access, so the workers, primarily young women who had recently emigrated from Europe, were trapped inside.
The building’s sole fire escape collapsed during rescue efforts. Many workers were fatally injured leaping from the building to escape the smoke and flames inside.
Last year, the American Society of Safety Professionals (ASSP) dedicated a stainless-steel memorial on the corner of Washington Place and Greene Street—the site of the fire in Manhattan. The ASSP was founded as the United Association of Casualty Inspectors months after the fire.
Unobstructed routes to visible and unlocked exit doors are now basic workplace safety protections.
OSHA enforcement, Dollar Tree settlement
The Occupational Safety and Health Administration’s (OSHA) exit routes and emergency planning regulations (29 Code of Federal Regulations (CFR) 1910 Subpart E) are some of its oldest standards, first promulgated on May 12, 1971 (36 Fed. Reg. 8,754).
The agency vigorously enforces its exit routes standards, §§1910.36 and 1910.37, frequently citing discount retailers like Dollar General, Dollar Tree, and Family Dollar for violations.
Last summer, OSHA and Dollar Tree Stores, Inc., the operator of discount retailers Dollar Tree and Family Dollar stores, entered into an agreement to settle the company’s OSHA citations.
Dollar Tree and Family Dollar stores, like their competitor, Dollar General, were often cited for safety violations that included blocked electrical panels, exit routes, or fire extinguishers, as well as improperly stacked boxes of merchandise.
Under the settlement agreement, Dollar Tree and Family Dollar are conducting a comprehensive, nationwide assessment of the root causes of violations OSHA has cited at multiple locations. The employer must identify causes and make operational changes to correct them within a 2-year period.
For now, Dollar Tree and Family Dollar stores must correct hazards like blocked electrical panels, exits, and fire extinguishers within 48 hours of OSHA’s notification. Dollar Tree, Inc., then must submit proof that the hazards were corrected.
If the employer fails to do so, Dollar Tree and Family Dollar will be subject to monetary assessments of $100,000 per day of violation, up to $500,000, as well as additional OSHA inspection and enforcement actions.
Dollar Tree Stores, Inc., signed an earlier corporatewide settlement agreement with OSHA in 2015 that expired in 2018. OSHA reached a similar settlement agreement with the Target Corporation in 2020, resolving violations that included blocked or obstructed access to emergency exits and fire exit routes and/or unsafe storage of materials in backrooms and storage areas at Target stores in Connecticut, Massachusetts, New Jersey, and New York.
Clear exit routes
During a fire or another emergency, your employees need a clear exit route and clearly marked and unlocked exit doors. Your employees’ access to an exit route must remain unobstructed by equipment or stored items, and they must be able to exit the workplace through doors that are unlocked from the inside.
Exits doors and exit routes, often referred to as “means of egress,” are some of the most fundamental worker safety protections in the United States. OSHA’s standards for exit routes and exit doors are unambiguous.
You can find OSHA’s general industry exit route and exit door regulations in 29 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 a person responsible for the emergency action plan.
The agency does recognize two industry consensus standards as alternatives to its emergency exit regulations. OSHA considers 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 an alternative to compliance with the OSHA rules.
OSHA’s regulations require most workplaces to have at least two designated exit routes. If you have a large building or a space configured in a way that would interfere with employees’, customers’, and visitors’ safe exit during an emergency, you may need to establish and maintain additional routes.
Ceilings along exit routes must be at least 7 feet (ft), 6 inches (in.) high, and exit routes must be at least 28 in. wide. 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. Materials, paint, or solutions must be renewed often enough to maintain their fire-retardant properties.
- Be maintained during any building alteration, construction, renovation, or repairs.
- Be arranged so that employees don’t have to travel toward a high-hazard area unless their path is effectively shielded from the high-hazard area.
- Be unobstructed by equipment, dead-end corridors, locked doors, or materials.
- Have adequate lighting for persons with normal vision.
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.” If the direction of the exit route and doors isn’t immediately obvious, signs must be posted indicating the correct direction of escape.
Exit doors must be free of decorations or signs that would obscure the visibility of the doors—no draperies or decorative hangings that would obstruct the view of or access to the exit route. Don’t place mirrors in or adjacent to an exit route, which could create confusion about the direction of the exit path. Exit doors may not be decorated in any way that would obscure or confuse the purpose of the doors.
Clear, unobscured exit routes and routine evacuation drills can save lives. Rick Rescorla, the head of security for Morgan Stanley at the World Trade Center, repeatedly drilled the company’s employees following the February 26, 1993, World Trade Center bombing and is credited with safely evacuating Morgan Stanley’s employees following the September 11, 2001, attacks.
Emergency action, fire prevention plans
The rest of Subpart E sets out requirements for emergency action and fire prevention plans.
An emergency action plan details actions that you and your employees will take in the event of a fire or another emergency. When developing an emergency plan for your facility, you may want to consult your frontline employees, managers, and supervisors, as well as local emergency response agencies.
Your emergency action plan should include, at a minimum:
- A preferred method of reporting a fire and other emergencies;
- Your facility’s evacuation policies and plans, detailing both what events trigger an evacuation and sheltering in place;
- Emergency escape procedures and designated evacuation routes with floor plans, workplace maps, and safe, refuge, or post-evacuation assembly areas;
- A chain of command during emergencies with names, job titles, departments, and telephone numbers of individuals both within and outside the company to contact for additional information, along with descriptions or explanations of their duties and responsibilities under the emergency action plan;
- Policies and procedures for workers who must remain to shut down or continue performing critical plant operations, operate fire extinguishers, or perform other essential services to ensure others’ safety; and
- First-aid or medical services and rescue duties and a list of employees designated to perform them.
Members of an emergency response team, if you have one, must be thoroughly trained for potential crises and need to know about any toxic hazards in the workplace.
Emergency response teams also must be trained in the following:
- Use of fire extinguishers;
- First aid, including cardiopulmonary resuscitation (CPR) and self-contained breathing apparatus (SCBA);
- Compliance with OSHA’s bloodborne pathogens standard;
- Shutdown and chemical spill response procedures;
- Hazardous materials emergency response; and
- Search-and-rescue procedures.
If you have 10 or fewer employees, your fire prevention plan may be communicated orally. All other workplaces must have written plans, which must be kept at the workplace where employees can review them.
The minimum requirements for a workplace fire prevention plan include:
- A list of all major fire hazards, potential ignition sources and their control, proper handling and storage procedures for hazardous materials, and the type of fire protection equipment necessary for controlling each major fire hazard;
- Procedures for controlling accumulations of flammable and combustible waste materials;
- Procedures for the regular maintenance of safeguards on heat-producing equipment for preventing the accidental ignition of combustible materials;
- The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires; and
- The name or job title of employees responsible for controlling fuel source hazards.
You must inform your employees of fire hazards when they’re first assigned to jobs that expose them. You also must review with each employee parts of the fire prevention plan necessary for their self-protection.
Emergency response rulemaking
Since 1980, OSHA has had a rule covering fire brigades—contractor or employee industrial fire departments. In February, the agency issued a notice of proposed rulemaking (NPRM) for a new emergency response standard to replace the nearly 44-year-old fire brigades rule.
The proposed emergency response standard would cover a wider range of private sector emergency responders, including firefighters, emergency medical service providers, and technical search-and-rescuers.
The agency is playing “catch-up” to industry practices. Emergency response has been covered by a patchwork of hazard-specific OSHA standards, none of which was intended as a comprehensive emergency response standard, according to the agency. Existing federal standards don’t address the full range of hazards emergency responders encounter and don’t reflect changes in performance specifications for protective clothing and equipment or improvements in safety and health practices incorporated into industry consensus standards.
If your contract or employee emergency response team has conformed to industry consensus standards, know that OSHA will soon catch up.