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OSHA 1910.37

Exit route maintenance requirements

Subpart E

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.37(a)(1): Are explosive or highly flammable furnishings allowed in exit routes?

No — exit routes must be kept free of explosive or highly flammable furnishings or decorations. This is required by 1910.37(a)(1).

  • Remove or replace any furniture, decorations, or temporary materials in exit routes that present an explosive or high-flammability hazard.
  • Keep records of corrective actions for workplace safety reviews.

Under 1910.37(a)(2): Can employees be required to travel toward a high-hazard area to reach an exit route?

No — employees must not have to travel toward a high-hazard area unless the path is effectively shielded by suitable partitions or physical barriers. This is required by 1910.37(a)(2).

  • If travel toward a hazard is unavoidable, install permanent partitions or barriers that provide effective shielding.
  • Evaluate layouts so normal exit access avoids hazardous zones during emergencies.

Under 1910.37(a)(3): May materials or equipment be placed in an exit route, even temporarily?

No — exit routes must be free and unobstructed, and no materials or equipment may be placed in them either permanently or temporarily. This is stated in 1910.37(a)(3).

  • Do not route exit access through rooms that can be locked (for example, bathrooms) or into dead-end corridors.
  • Provide stairs or ramps where the exit route is not substantially level.

Under 1910.37(a)(4): Do safeguards like sprinkler systems, fire doors, and exit lighting have to work at all times?

Yes — safeguards designed to protect employees during an emergency (for example, sprinkler systems, alarm systems, fire doors, exit lighting) must be in proper working order at all times. See 1910.37(a)(4).

  • Implement routine maintenance and testing schedules and document results.
  • If a protection system is out of service during repairs, provide equivalent temporary fire protection until the system is restored.

Under 1910.37(b)(1): What does 'adequately lighted' for exit routes mean in practice?

An exit route must be lit so that an employee with normal vision can see along it. That is the requirement in 1910.37(b)(1).

  • Use fixtures or emergency lighting that provide continuous visibility during both normal and emergency conditions.
  • Inspect and replace burned-out lamps promptly and test backup power or battery lighting periodically.

Under 1910.37(b)(6): How bright must exit signs be and what other illumination features are required?

Each exit sign must be illuminated to a surface value of at least five foot-candles (54 lux) by a reliable light source and be distinctive in color, as required by 1910.37(b)(6).

  • Use reliable lighting sources and test their backup power regularly.
  • Consider self-luminous or electroluminescent signs that meet the minimum luminance requirements when appropriate.

Under 1910.37(b)(7): What are the required size and stroke width for the letters on an 'Exit' sign?

Each exit sign must have the word 'Exit' in plainly legible letters not less than six inches (15.2 cm) high, with the principal strokes not less than three-fourths of an inch (1.9 cm) wide, per 1910.37(b)(7).

  • Inspect signs to confirm they meet these dimensions and remain clearly legible.
  • Replace signs that have faded, been painted over, or otherwise obscured.

Under 1910.37(b)(4): When must directional exit signs be posted and what visibility rules apply?

If the direction of travel to the exit or exit discharge is not immediately apparent, signs must be posted along the exit access indicating the direction to the nearest exit, and the line-of-sight to an exit sign must be clearly visible at all times, as required by 1910.37(b)(4).

  • Place directional signs at decision points and ensure nothing blocks the view of the sign.
  • Test visibility during both normal and emergency lighting conditions.

Under 1910.37(b)(5): What must be done with doors or passages that could be mistaken for exits?

Doorways or passages that could be mistaken for an exit must be marked 'Not an Exit' or similar, or identified by a sign indicating their actual use, under 1910.37(b)(5).

  • Mark closets, storerooms, and other non-exit doors so occupants do not waste time during an emergency.
  • Keep the signage clear, legible, and illuminated if necessary.

Under 1910.37(c): How often must fire-retardant paint or treatment be renewed on exit routes?

Fire-retardant paints or solutions must be renewed as often as necessary to maintain their fire-retardant properties, per 1910.37(c).

  • Inspect treated surfaces periodically and after any renovation or damage.
  • Keep maintenance records showing renewal dates and products used.

Under 1910.37(d)(1): Can employees occupy parts of a building during new construction before required exit routes are completed?

No — during new construction employees must not occupy a workplace until the exit routes required by this subpart are completed and ready for employee use for the portion of the workplace they occupy, as stated in 1910.37(d)(1).

  • Plan construction in phases so occupant areas have compliant exit routes before use.
  • Do not allow temporary occupancy unless required exits are available and functional.

Under 1910.37(d)(2): During repairs or alterations, when may employees occupy a workplace?

Employees may occupy a workplace during repairs or alterations only if the exit routes required by this subpart are available and existing fire protections are maintained, or an alternate fire protection system providing an equivalent level of safety is furnished, as required by 1910.37(d)(2).

  • If you temporarily take a protection system out of service, document the alternate protections you provide.
  • Coordinate work schedules to avoid compromising required exits.

Under 1910.37(d)(3): Can employees be exposed to extra flammable or explosive hazards during construction, repairs, or alterations?

No — employees must not be exposed to hazards from flammable or explosive substances or equipment used during construction, repairs, or alterations that are beyond the normal permissible conditions or that would impede exiting the workplace, per 1910.37(d)(3).

  • Assess and control sources of flammable materials and remove or isolate them from exit routes.
  • Use safe storage and ventilation practices to prevent accumulation of hazardous vapors.

Under 1910.37(e): Is an employee alarm system required and what standard governs it?

Yes — employers must install and maintain an operable employee alarm system with a distinctive signal to warn employees of fire or other emergencies, unless employees can promptly see or smell a hazard; the alarm system must comply with 1910.165, as required by 1910.37(e).

  • Follow the alarm system performance, testing, and maintenance requirements in 1910.165.
  • Ensure alarm signals are distinctive and understood by all workers (training and drills).

Under 1910.37(b)(3): May exit route doors have decorations or signs on them?

No — each exit route door must be free of decorations or signs that obscure the visibility of the exit route door, in accordance with 1910.37(b)(3).

  • Keep exits unblocked and signage limited to required exit identification.
  • Regularly inspect doors to ensure nothing reduces their visibility or accessibility.

Under 1910.37(a)(3): Is it acceptable for exit access to go through a bathroom or other lockable room?

No — the exit access must not go through a room that can be locked, such as a bathroom, to reach an exit or exit discharge, as stated in 1910.37(a)(3).

  • Reroute exit access so occupants need not enter lockable rooms to reach an exit.
  • If changes are made, update evacuation maps and employee training accordingly.

Under 1910.37: Are self-luminous or electroluminescent exit signs allowed and what is the minimum luminance?

Yes — self-luminous or electroluminescent signs are permitted provided they have a minimum luminance surface value of at least 0.06 footlamberts (0.21 cd/m2), as allowed under 1910.37.

  • Verify manufacturer specifications to confirm signs meet the luminance requirement.
  • Maintain and test such signs periodically to ensure ongoing visibility.

Under 1910.37: What must an employer do if exit lighting or other emergency safeguards are temporarily out of service during repairs?

If exit lighting or other required emergency safeguards are temporarily out of service during repairs, the employer must ensure required exit routes remain available and either maintain existing fire protections or furnish alternate protections that provide an equivalent level of safety, per 1910.37(d)(2) and the general requirement in 1910.37(a)(4).

  • Provide temporary lighting, additional staff to guide evacuation, or other measures that compensate for the outage.
  • Document the outage, the temporary measures used, and the plan to restore the safeguard.

Under 1910.37(a)(3): Are stairs or ramps required for exit routes that are not substantially level, and when?

Yes — where an exit route is not substantially level, stairs or a ramp must be provided to maintain a usable exit route, as required by 1910.37(a)(3).

  • Design stairs and ramps to meet applicable dimension and safety requirements and keep them clear at all times.
  • Inspect and maintain handrails, treads, and landings per other applicable OSHA requirements.