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OSHA 1910.36

Exit route design requirements

Subpart E

28 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.36(a)(1), must exit routes be permanent parts of the workplace or can temporary corridors count as exits?

Exit routes must be permanent parts of the workplace; temporary corridors do not satisfy the permanence requirement. Employers must ensure that an exit route is a permanent installation in the workplace as required by 1910.36(a)(1).

  • If you need temporary egress during construction or renovation, provide code‑compliant temporary exits and document how they meet means-of-egress requirements.
  • Consult the full Design and construction requirements for exit routes for related provisions on openings, doors, and discharge.

Under 1910.36(a)(2), what fire-resistance rating is required for construction that separates an exit from the rest of the workplace?

If an exit connects three or fewer stories, the separating construction must have a one-hour fire resistance rating; if it connects four or more stories, it must have a two-hour rating. This is required by 1910.36(a)(2).

  • Ensure materials, assemblies, and fire doors used in the separation meet the stated hour‑ratings.
  • Fire doors and their frames/hardware also must be listed or approved by a nationally recognized testing laboratory as discussed in 1910.155(c)(3)(iv)(A) and the definition of an NRTL in 1910.7.

Under 1910.36(a)(3), how many openings are allowed into an exit and what protection must they have?

An exit may have only the openings necessary for access or discharge, and any opening into an exit must be protected by a self‑closing fire door that remains closed or automatically closes on alarm. This requirement is stated in 1910.36(a)(3).

  • Limit openings to only those needed for access or exit discharge.
  • Protect permitted openings with self‑closing fire doors that close in an emergency (e.g., on fire alarm activation).
  • When using listed fire doors, confirm they are listed under 1910.155(c)(3)(iv)(A) and tested by a nationally recognized testing laboratory.

Under 1910.36(b)(1), when are two exit routes required and how should they be located?

At least two exit routes are required to permit prompt evacuation, and they must be located as far apart as practical so one blocked route won't prevent evacuation by the other. This is required by 1910.36(b)(1).

  • Two exits are the minimum unless the single-exit exception applies under 1910.36(b)(3).
  • The spacing should reduce the chance that the same hazard (e.g., fire or smoke) blocks both routes.
  • For assistance on how many exits a workplace needs, consult NFPA 101 or the International Fire Code as referenced in the note to 1910.36(b).

Under 1910.36(b)(2), when must more than two exit routes be provided?

More than two exit routes must be provided when factors like employee count, building size, occupancy type, or workplace layout mean two exits would not allow all employees to evacuate safely. This requirement is set out in 1910.36(b)(2).

  • Evaluate maximum occupant load and egress capacity to determine if additional exits are needed.
  • Use NFPA 101-2009 or the IFC-2009 (referenced in the note to 1910.36(b)) for detailed methods to size exits and calculate required numbers.

Under 1910.36(b)(3), when can a single exit route be used?

A single exit route is permitted only when the number of employees, building size, occupancy, and layout are such that all employees can evacuate safely during an emergency. This allowance is in 1910.36(b)(3).

  • Employers should document the analysis showing safe evacuation with a single exit (e.g., occupant load, travel distance, and arrangement).
  • Refer to NFPA 101 or the IFC for methodologies used to justify a single exit, as noted in 1910.36(b).

Under 1910.36(c)(1)-(2), where must exit discharges lead and what size must the discharge area be?

Each exit discharge must lead directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside, and that space must be large enough to accommodate likely building occupants. This is required by 1910.36(c)(1) and 1910.36(c)(2).

  • Design exit discharge locations to prevent bottlenecks and ensure occupants can move away from the building safely.
  • For stairs that continue past the discharge level, follow 1910.36(c)(3) to provide interruptions and clear direction to the discharge.

Under 1910.36(c)(3), how should exit stairs that continue beyond the exit discharge level be handled?

If exit stairs continue beyond the level of exit discharge, they must be interrupted at that level by doors, partitions, or other effective means that clearly indicate the direction to the exit discharge. This requirement is in 1910.36(c)(3).

  • Use barriers or signage that make the direction to the exit discharge obvious and prevent confusion.
  • Ensure these interruptions do not create additional hazards or block egress.

Under 1910.36(d)(1), must exit route doors be unlocked, and what does "openable from the inside without keys" mean in practice?

Yes — exit route doors must be openable from the inside at all times without keys, tools, or special knowledge so employees can exit quickly. This is required by 1910.36(d)(1).

  • Doors should be equipped with hardware (like lever handles or panic hardware) that any occupant can operate without training.
  • Do not lock egress doors with mechanisms that require keys or hidden release procedures during normal occupancy.

Under 1910.36(d)(2), are door alarms or devices that could fail and restrict emergency use allowed on exit route doors?

No — exit route doors must be free of devices or alarms that could restrict emergency use of the route if the device or alarm fails. This is stated in 1910.36(d)(2).

  • Devices that could inadvertently block exit (for example, electrically locked doors without fail‑safe release) are not permitted unless they cannot fail in a way that restricts egress.
  • Use alarms or access control only where they do not prevent or delay emergency egress (e.g., exits with panic hardware that allows easy exit even if alarm sounds).

Under 1910.36(d)(3), may exit route doors be locked from the inside in any facilities?

Exit route doors may be locked from the inside only in mental, penal, or correctional facilities, and then only if supervisory personnel are continuously on duty and the employer has a plan to remove occupants during an emergency. This exception is in 1910.36(d)(3).

  • For these facilities, maintain continuous supervision and an effective emergency evacuation plan specific to occupant removal.
  • All other workplaces must keep exit route doors openable from the inside without special knowledge or keys as required by 1910.36(d)(1).

Under 1910.36(d)(1) and (d)(2), are panic bars or devices that lock only from the outside allowed on exit discharge doors?

Yes — a device such as a panic bar that locks only from the outside is permitted on exit discharge doors, provided the door remains openable from the inside without keys, tools, or special knowledge and does not rely on alarms/devices that could fail and restrict egress. See 1910.36(d)(1) and 1910.36(d)(2).

  • Panic hardware is a common compliance solution because it allows rapid interior egress while restricting entry from outside.
  • Confirm that any locks release without special knowledge and any alarms do not prevent exit if they fail.

Under 1910.36(e)(1)-(2), what type of door must connect a room to an exit route and when must it swing in the direction of exit travel?

A side‑hinged door must be used to connect any room to an exit route, and that door must swing in the direction of exit travel if the room is designed for more than 50 people or is a high hazard area. This is required by 1910.36(e)(1) and 1910.36(e)(2).

  • "High hazard" refers to areas with contents likely to burn very rapidly or explode.
  • For rooms under the thresholds, ensure doors remain side‑hinged and openable without special tools.

Under 1910.36(f), how should exit route capacity be sized relative to occupant load?

Exit routes must support the maximum permitted occupant load for each floor they serve; the width and components must be sufficient for the occupant load. This requirement appears in 1910.36(f)(1).

  • Use occupant load calculations in NFPA 101-2009 or IFC-2009 (referenced in the note to 1910.36(f)) to size exits.
  • Avoid reductions in exit capacity in the direction of travel; see 1910.36(f)(2).

Under 1910.36(f)(2), can the capacity (width) of an exit route decrease in the direction of exit travel?

No — the capacity of an exit route may not decrease in the direction of exit travel toward the exit discharge. This prohibition is stated in 1910.36(f)(2).

  • Design exit paths so the width is the same or increases as people move to the discharge to prevent bottlenecks.
  • Check that any intermediate doors, corridors, or stairs do not reduce the effective egress width below the required minimum.

Under 1910.36(g)(1), what is the minimum ceiling height for an exit route and how must ceiling projections be treated?

The ceiling of an exit route must be at least 7 feet 6 inches (2.3 m) high, and any projection from the ceiling must not reach less than 6 feet 8 inches (2.0 m) above the floor. This is set out in 1910.36(g)(1).

  • Keep hanging fixtures, ducts, or pipes high enough so they don't reduce clearance below the 6'8" point.
  • Measure clearances from the finished floor to the lowest point of the projection.

Under 1910.36(g)(2)-(3), what are the minimum width requirements for exit accesses and exits?

An exit access must be at least 28 inches (71.1 cm) wide at all points, and the width of an exit route overall must be sufficient to accommodate the maximum permitted occupant load for each floor served. These requirements are in 1910.36(g)(2) and 1910.36(g)(3).

  • Where there is only one exit access, the exit and exit discharge width must be at least equal to that exit access width per 1910.36(g)(2).
  • Use occupant load calculations to determine if wider exits are required to handle the permitted number of occupants.

Under 1910.36(g)(4), can objects project into exit routes and reduce available width?

Objects are allowed to project into exit routes only if they do not reduce the exit route width below the minimum required; they must not reduce the width to less than the minimums in the standard. This is stated in 1910.36(g)(4).

  • Keep permanent and temporary obstructions out of the clear egress width.
  • Measure egress widths at the narrowest point, ensuring they meet the minimums (e.g., 28 inches for exit access) and the calculated capacity for the occupant load.

Under 1910.36(h), what special rules apply to outdoor exit routes (guardrails, covering, slope, dead-ends)?

Outdoor exit routes must meet indoor minimum height and width requirements and also must have guardrails if a fall hazard exists, be covered if snow or ice accumulation is likely (unless removal is guaranteed), be reasonably straight with smooth, level walkways, and not have dead‑end segments longer than 20 feet. These requirements are listed in 1910.36(h) and its subparts 1910.36(h)(1)1910.36(h)(4).

  • If fall exposure exists, install guardrails per 1910.36(h)(1).
  • Where ice/snow accumulation is likely, cover the route or ensure timely removal as per 1910.36(h)(2).
  • Do not allow outdoor dead-ends over 20 feet as specified in 1910.36(h)(4).

Under 1910.36(g)(2) and the stair width guidance letter of 2024-10-17, should handrails be counted as obstructions when measuring exit stair width?

No — handrails are not considered vertical barriers or obstructions for measuring stair width; stair width is measured between vertical barriers and handrails do not reduce the required width. This is consistent with 1910.36(g)(2) and clarified in OSHA's stair width measurement guidance (2024-10-17).

  • For means of egress, measure clear stair width between vertical barriers such as walls or guardrails (handrails are not vertical barriers).
  • Remember stair width rules for standard stairs under other sections (e.g., 1910.25) differ from egress requirements; the 2024 letter explains how to measure in practice.

Under 1910.36 and 1910.155(c)(3)(iv)(A), what requirements apply to fire doors used in exit separations?

Fire doors, including their frames and hardware, must be listed or approved by a nationally recognized testing laboratory; the terms "listed" and the definition of an NRTL are addressed in 1910.155(c)(3)(iv)(A) and 1910.7. See also the exit separation requirements in 1910.36(a)(2).

  • Use only listed fire doors and components for rated exit separations to meet the hour‑rating requirements.
  • Keep manufacturer installation instructions and listing documentation on file as evidence of compliance.

Under 1910.36(c)(3), how should direction of travel be indicated where exit stairs pass through other levels?

Where exit stairs continue past the level of exit discharge, use doors, partitions, or other effective means to interrupt the stair and clearly indicate the direction of travel to the exit discharge. This requirement is in 1910.36(c)(3).

  • Effective means can include physical barriers combined with directional signage and lighting to guide evacuees.
  • Ensure interruptions do not create confusion or delay egress during an emergency.

Under 1910.36(g), can the minimum 28-inch width requirement be reduced at any point along an exit access?

No — an exit access must be at least 28 inches wide at all points; you cannot reduce below that minimum anywhere along the access. This is required by 1910.36(g)(2).

  • If an access narrows due to structural features, remodel to widen the path or provide an alternative compliant route.
  • Remember that when only one exit access exists, the exit and discharge must be at least equal in width to that access per the same paragraph.

Under 1910.36(h)(2), when is an outdoor exit route required to be covered for snow or ice?

An outdoor exit route must be covered if snow or ice is likely to accumulate along the route, unless the employer can demonstrate that any accumulation will be removed before it presents a slipping hazard. This rule appears in 1910.36(h)(2).

  • If you cannot guarantee timely snow/ice removal, provide a covered walkway or comparable protection.
  • Document your snow/ice control plan and procedures to show compliance if asked by an inspector.

Under 1910.36(e)(2), does a door to an exit have to swing out if the room is a high hazard area even with fewer than 50 occupants?

Yes — a door must swing in the direction of exit travel for any room that is a high hazard area, regardless of the occupant count; the occupant-count threshold applies separately for rooms designed to hold more than 50 people. This is required by 1910.36(e)(2).

  • Identify high hazard areas (contents likely to burn rapidly or explode) and ensure side‑hinged doors swing outward in the direction of exit travel.
  • For rooms over 50 occupants, the outward swing is required even if not a high hazard area.

Under 1910.36(f) and the note referencing NFPA 101/IFC, how should an employer determine occupant load for sizing exits?

Employers should size exits based on the maximum permitted occupant load for each floor, using accepted references such as NFPA 101-2009 or IFC-2009 as noted in the standard's guidance. The requirement to support occupant load appears in 1910.36(f)(1), and the note to paragraph (f) specifically refers to NFPA 101-2009 and IFC-2009 for help determining occupant load.

  • Use the occupant load factor and floor area methods in NFPA or IFC to calculate required egress widths and number of exits.
  • Keep documentation of your calculations and code references to demonstrate compliance.

Under 1910.36(g)(1) and related guidance, how should you measure clearance under ceiling projections in an exit route?

Measure the clearance from the finished floor to the lowest point of the projection; any projection must not extend lower than 6 feet 8 inches (2.0 m) above the floor in an exit route, and the ceiling must be at least 7 feet 6 inches (2.3 m). These measurements come from 1910.36(g)(1).

  • Check lighting, sprinkler, or HVAC elements that hang from ceilings and adjust them to maintain required clearance.
  • Document field measurements during inspections to confirm compliance.

Under 1910.36(h)(4), what is the maximum permitted length of a dead-end outdoor exit route?

An outdoor exit route may not have a dead-end longer than 20 feet (6.2 m). This limit is specified in 1910.36(h)(4).

  • Design outdoor egress paths to avoid dead‑ends greater than 20 feet, or provide alternative means to eliminate the dead‑end.
  • For complex sites, map egress routes to ensure no outdoor exit path exceeds the dead‑end limitation.