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OSHA 1910.34

Exit routes coverage and definitions

Subpart E

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.34(a), which employers and workplaces are covered by the exit route and emergency planning rules?

All employers in general industry are covered except for mobile workplaces such as vehicles or vessels. See 1910.34(a) for the coverage statement that 1910.34–1910.39 apply to workplaces in general industry and exclude mobile workplaces.

Under 1910.34(b), what do the exit route rules require employers to provide?

The rules require employers to provide minimum safe exit routes and the minimum elements of emergency action plans and fire prevention plans so employees can evacuate safely in an emergency. See 1910.34(b) which explains that 1910.34–1910.39 cover minimum requirements for exit routes, emergency action plans, and fire prevention plans.

Under 1910.34(c), what is an "exit" and what is an example?

An "exit" is the portion of an exit route that is generally separated from other areas to provide a protected way of travel to the exit discharge; an example is a two-hour fire resistance-rated enclosed stairway leading from an upper floor to the outside. See the definition of "Exit" in 1910.34(c) and the example given there of a two-hour fire-resistance-rated enclosed stairway.

Under 1910.34(c), what is "exit access" and can you give an example?

"Exit access" is the portion of an exit route that leads to an exit; an example is a corridor on a floor that leads to an enclosed stairway. See the definition of "Exit access" in 1910.34(c) and the corridor-to-stairway example provided there.

Under 1910.34(c), what is "exit discharge" and can you give an example?

"Exit discharge" is the part of the exit route that leads directly outside or to a safe public way, such as the door at the bottom of an enclosed stairway that opens to the outside. See the definition of "Exit discharge" in 1910.34(c) and its example of a door at the bottom of a two-hour fire-resistance-rated enclosed stairway.

Under 1910.34(c), what is an "exit route" and what are its component parts?

An "exit route" is a continuous and unobstructed path of exit travel from any point in a workplace to a place of safety and consists of three parts: the exit access, the exit, and the exit discharge. See the definition of "Exit route" in 1910.34(c) which states an exit route includes all vertical and horizontal areas along the route.

Under 1910.34(c), does an exit route include vertical and horizontal areas along the route?

Yes — an exit route includes all vertical and horizontal areas along the route. See the statement in the definition of "Exit route" in 1910.34(c) confirming that vertical and horizontal areas along the route are included.

Under 1910.34(c), how is "occupant load" defined and how should it be calculated?

"Occupant load" is the total number of persons that may occupy a workplace or portion of a workplace at any one time, and it is calculated by dividing the gross floor area by the occupant load factor for that occupancy type. See the definition of "Occupant load" and the calculation method in 1910.34(c), and note that the occupant load factors are provided in NFPA 101-2009 and IFC-2009 which are incorporated by reference via 1910.6.

Under 1910.34(c), what is a "refuge area" and what are the two ways it can be provided?

A "refuge area" is either (1) a space along an exit route protected by a barrier with at least a one-hour fire resistance rating, or (2) a floor with at least two spaces separated by smoke-resistant partitions in a building protected throughout by an automatic sprinkler system that complies with 1910.159. See the definition of "Refuge area" in 1910.34(c) which lists these two options.

Under 1910.34(c), what does "electroluminescent" mean for exit sign lighting?

"Electroluminescent" means a light-emitting capacitor where alternating current excites phosphor atoms between conductive surfaces to produce light, and this describes one acceptable type of exit sign illumination. See the definition of "Electroluminescent" in 1910.34(c).

Under 1910.34(c), what does "self-luminous" mean and are batteries acceptable as the self-contained power source?

A "self-luminous" light source is one illuminated by a self-contained power source (for example, tritium) that operates independently of external power, and batteries are not acceptable as self-contained power sources. See the definition of "Self-luminous" and the specific statement that "Batteries are not acceptable self-contained power sources" in 1910.34(c).

Under 1910.34, do the exit route and emergency planning rules apply to mobile workplaces such as vehicles or vessels?

No — the exit route and emergency planning rules in 1910.34–1910.39 do not apply to mobile workplaces such as vehicles or vessels. See the coverage statement in 1910.34(a) which explicitly excludes mobile workplaces.

Under 1910.34 and related sections, why is knowing the occupant load important when planning exits?

Knowing the occupant load is important because it determines how many and how large exit routes and exits must be to safely evacuate everyone; occupant load guides exit sizing and means-of-egress planning. See the definition and calculation method for "Occupant load" in 1910.34(c) and the referenced occupant load factors in NFPA 101-2009 and IFC-2009 via 1910.6.

Under 1910.34(c), what is a "high hazard area"?

A "high hazard area" is an area inside a workplace where operations include high-hazard materials, processes, or contents that present greater risk. See the definition of "High hazard area" in 1910.34(c).

Under 1910.34, does an exit route end at a "place of safety," and what counts as a place of safety?

Yes — an exit route leads to a place of safety, which can include a refuge area, an outside street, walkway, refuge area, public way, or open space with access to the outside. See the definition of "Exit route" and the examples of exit discharge destinations in 1910.34(c).

Under 1910.34(c) and 1910.159, when does option (2) for a refuge area require an automatic sprinkler system?

Option (2) for a refuge area requires that the building be protected throughout by an automatic sprinkler system that complies with 1910.159. See the second definition option for "Refuge area" in 1910.34(c) which explicitly references compliance with 1910.159.

Under 1910.34 and related fit-for-purpose guidance, how should stair width be measured for compliance with stair standards and are handrails considered obstructions?

Handrails are not considered vertical barriers or obstructions when measuring standard stair width; stair width is measured between vertical barriers such as walls or guardrails. See the OSHA letter of interpretation "Stair width measurement guidance" at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-17 and the stairway requirement in 1910.25. That interpretation also notes that means-of-egress width requirements are addressed separately in 1910.35.

Under 1910.34, can an employer use NFPA 101 or the International Fire Code to determine occupant load?

Yes — the standard directs employers to calculate occupant load using occupant load factors found in NFPA 101-2009 and IFC-2009, which are incorporated by reference via 1910.6. See the occupant load instruction in 1910.34(c) and the incorporation note referencing NFPA 101-2009 and IFC-2009 through 1910.6.

Under 1910.34, are exit routes required to be continuous and unobstructed, and what does that mean in practice?

Yes — exit routes must be a continuous and unobstructed path from any point in the workplace to a place of safety, meaning employers must keep corridors, stairways, and exit doors free of obstructions that would block or delay evacuation. See the definition of "Exit route" in 1910.34(c) which requires a continuous and unobstructed path of exit travel.

Under 1910.34, does the definition of "exit" include examples with fire-resistance ratings, and why is that important?

Yes — the standard includes an example of an exit being a two-hour fire resistance-rated enclosed stairway, which emphasizes that some exits must be constructed to resist fire for a set period to protect evacuees during evacuation. See the example of a two-hour fire resistance-rated enclosed stairway in 1910.34(c).