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OSHA 1910.33

Exit routes and emergency plans

Subpart E

26 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.34, who is covered by the exit routes and emergency plans requirements?

Every employer is covered by the exit routes and emergency plans requirements; these rules apply to workplaces that fall under 29 CFR part 1910. See Coverage and definitions in 1910.34 and the general scope at 1910.

Under 1910.36, what basic requirements must exit routes meet?

Exit routes must provide a continuous and unobstructed path of travel to a safe area and meet the specific design and construction rules in the standard. Employers must ensure exit routes are properly located, sized, and constructed so employees can leave the workplace safely; see Design and construction requirements for exit routes in 1910.36 and the general 1910 coverage.

Under 1910.36(b), how many exit routes do I need for my workplace?

You must provide an adequate number of exit routes based on the workplace layout and the number of employees so that workers can evacuate safely. The standard requires enough exits to avoid bottlenecks and to provide alternate paths if one route is blocked — see Number of exit routes must be adequate in 1910.36(b) for the criteria to determine adequacy.

Under 1910.36(d), can exit doors be locked while the workplace is occupied?

No — an exit door must be unlocked when the building is occupied so employees can exit without delay. Employers must follow the rule that exit doors remain unlocked during occupancy; see the unlocked-exit-door requirement in 1910.36(d).

Under 1910.36(e), may a sliding or recessed door be used as an exit door?

No — a side-hinged exit door must be used for exit doors unless the standard allows a specific exception; employers should provide side-hinged doors where required by 1910.36(e).

Under 1910.36(f), how do I know if my exit route capacity is adequate for my employees?

Exit route capacity must be sufficient to handle the number of employees who will use it so that everyone can evacuate safely and without congestion; employers must size exits and pathways to the required capacity in 1910.36(f).

Under 1910.36(g), what rules apply to the minimum height and width of exit routes?

Exit routes must meet the minimum height and width requirements specified in the exit-route design rules so people can pass safely; see the dimensional requirements in 1910.36(g) for the applicable standards for heights and widths.

Under 1910.36(h), can an exit route be entirely outdoors?

Yes — an outdoor exit route is permitted if it meets the design and construction requirements of the exit-route standard and provides a safe means to a public way or safe area; see Outdoor exit route provision in 1910.36(h).

Regarding 1910.37(a), can exit routes be used for storage or other obstructions?

No — employers must minimize hazards and keep exit routes clear of storage, equipment, or other obstructions so employees can evacuate safely. Exit routes must be maintained free from impediments as required by 1910.37(a).

Under 1910.37(b), what are the lighting and marking requirements for exit routes?

Exit routes must have adequate and appropriate lighting and marking so employees can find and use exits during an emergency; employers must provide and maintain this lighting and marking per 1910.37(b).

Under 1910.37(c), do painted finishes on exit routes need maintenance for fire retardancy?

Yes — if paints or surface solutions are used for their fire-retardant properties on exit-route components, those properties must be maintained so the materials continue to perform as intended; see fire retardant maintenance in 1910.37(c).

Under 1910.37(d), what must be done with exit routes during construction, repairs, or alterations?

Exit routes must be maintained and kept usable during construction, repairs, or alterations so employees still have safe paths for escape; employers must follow the continuity and maintenance rules in 1910.37(d).

Under 1910.37(e), what are the requirements for employee alarm systems?

Employee alarm systems used to signal emergencies must be operable and effective at notifying employees so they can take action; ensure alarms are maintained, tested, and meet the system requirements in 1910.37(e).

Under 1910.38, what are the minimum elements that must be included in an Emergency Action Plan (EAP)?

An Emergency Action Plan must include clear procedures for reporting emergencies, evacuation procedures and routes, procedures for accounting for employees after evacuation, rescue and medical duties for trained staff, designated persons to contact, and any special procedures for employees who must remain to operate critical systems. Employers should assemble these minimum elements as required by Minimum elements of an emergency action plan in 1910.38(c) and review general application at 1910.38(a)-(b).

Under 1910.38(b), when must an Emergency Action Plan be written versus just communicated orally?

The standard requires employers to have either a written or an oral Emergency Action Plan as appropriate for the workplace; employers should determine whether a written plan is needed based on their size and complexity and provide oral instructions where a written plan is not required, following Written and oral emergency action plans in 1910.38(b).

Under 1910.38(e), what training is required for employees under an Emergency Action Plan?

Employees must be trained on the emergency procedures that affect their duties — this includes alarm recognition, evacuation routes, individual responsibilities, and how to report emergencies; employers must provide initial and periodic training as required by Training under 1910.38(e).

Under 1910.38(f), how often should an employer review their Emergency Action Plan?

Employers must review the Emergency Action Plan periodically and whenever there are changes in the workplace that could affect the plan so it remains effective; see the review requirement at 1910.38(f).

Under 1910.39, when is a Fire Prevention Plan required and what must it include?

A Fire Prevention Plan is required where the standard applies and must identify fire hazards, procedures to control and handle combustible materials, maintenance of equipment to prevent ignition, and employee information about fire hazards and safe practices; employers should prepare the plan following Fire prevention plan requirements in 1910.39(c) and the application rules in 1910.39(a)-(b).

Under 1910.39(d), what information about fire prevention must employers give employees?

Employers must inform employees about the fire hazards they may face, proper handling of hazardous materials and equipment, and the plan’s procedures for preventing and responding to fires; see the employee information requirements at 1910.39(d).

Under 1910.35, when can an employer follow alternate exit-route codes instead of OSHA exit-route requirements?

Employers may comply with alternate exit-route codes when those codes provide an equivalent or greater level of protection and the employer documents how the alternate code meets or exceeds OSHA requirements; see Compliance with Alternate Exit Route Codes in 1910.35 and the overall exit-route rules in 1910.36.

Under 1910.36 and related guidance, do handrails count as obstructions when measuring stair width for egress?

No — handrails are not considered obstructions or vertical barriers when measuring required stair width; measure stair width between vertical barriers (such as walls or guardrails) rather than between handrails, consistent with stairway guidance and the discussion in [1910.36] (exit-route rules) and stair width measurement guidance that interprets related stair standards such as 1910.25.

Under 1910.37, what must employers do to ensure exit signs and emergency lighting remain effective?

Employers must maintain exit signs and emergency lighting so they are illuminated and visible during normal and emergency conditions, test and repair systems as needed, and ensure markings remain legible and unobstructed in accordance with 1910.37(b).

Under 1910.37, are employee alarm systems required to be audible or visual for all employees?

Employee alarm systems must be appropriate for the workplace so that all employees can be warned — alarms should be audible, visual, or both as needed to ensure they are perceived above ambient conditions and are effective; see Employee alarm system requirements in 1910.37(e).

Under 1910.36 and 1910.37, what should an employer do if an exit route is temporarily blocked for repairs?

If an exit route must be taken out of service for repairs or construction, the employer must provide and clearly mark an alternate unobstructed exit route and communicate the change to employees so safe evacuation remains possible, as required by 1910.37(d) and the exit-route continuity rules in 1910.36.

Under 1910.36, can exit routes have steps or changes in level, and what should employers consider?

Exit routes may include stairs or level changes, but employers must design and maintain them to provide a continuous, usable path and meet the dimensional and construction requirements in 1910.36 and maintain safe stair conditions per related standards such as 1910.25 and guidance on stair measurement in the stair width interpretation.

Under 1910.38 and 1910.39, how do Emergency Action Plans differ from Fire Prevention Plans?

An Emergency Action Plan (EAP) lays out how employees should respond during an emergency (evacuation procedures, alarms, assigned responsibilities), while a Fire Prevention Plan identifies and controls fire hazards and safe handling and storage practices; employers must prepare each plan according to their separate minimum elements in 1910.38 and 1910.39.