Subpart E Means of Egress

1. Subpart E Means of Egress

2. 1910.34(c) Definitions • Exit means that portion of an exit route that is generally separated from other areas to provide a protected way of travel to the exit discharge. • Exit access means that portion of an exit route that leads to an exit. • Exit discharge means the part of the exit route that leads directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside.

3. 1910.34(c) Definitions • Exit route* means a continuous and unobstructed path of exit travel from any point within a workplace to a place of safety (including refuge areas). An exit route consists of three parts: • The exit access; • The exit; and, • The exit discharge. • *Equivalent to the term Means of Egress in the Life Safety Code and most local building and fire codes

4. 1910.35 Compliance with NFPA 101-2000, Life Safety Code • An employer who demonstrates compliance with the exit route provisions of NFPA 101-2000, the Life Safety Code, will be deemed to be in compliance with the corresponding requirements in § § 1910.34, 1910.36, 1910.37 NFPA

5. 10/01/1993 - NFPA, Life Safety Code and Means of Egress • You requested a written confirmation from the Occupational Safety and Health Administration (OSHA) on whether an employer who meets the National Fire Protection Association (NFPA) 101, Life Safety Code, is considered in compliance with OSHA's Subpart E-Means of Egress standard, 29 CFR 1910.35 through 1910.38.

6. 10/01/1993 - NFPA, Life Safety Code and Means of Egress • Employers who meet the requirements of NFPA-101 are considered in compliance with 29 CFR 1910, Subpart E. Employer compliance with revised national consensus standards, such as, NFPA-101, which provide equal or greater employee protection to that provided by an earlier version promulgated into OSHA standards, would be acceptable to OSHA.

7. 1910.36(b) The number of exit routes must be adequate • (b)(1) At least two exit routes must be available in a workplace to permit prompt evacuation during an emergency: • The exit routes must be located as far away as practical from each other so that if one exit route is blocked by fire or smoke, employees can evacuate using the second exit route

8. 1910.36 (b) Fundamental Requirements • Buildings maintained to provide free and unobstructed egress from all parts of the building at all times when it is occupied. • No lock or fastening to prevent free escape from the inside of any building shall be installed except in mental, penal, or corrective institutions.

9. Standard Interpretations 06/29/1994 - Key to open locked exits • The following guidance is offered to clarify 29 CFR 1910.36(b)(4) with respect to the definition of "occupied". The 1985 and 1991 editions of NFPA 101, the Life Safety Code, define a building as being "occupied" when more than 10 persons are in it. • OSHA will not narrow its scope of coverage of 1910.36 to accommodate NFPA's 1985 and the 1991 definition of "occupied". Such an accommodation would provide a level of protection for employees less than that which is afforded by the 1970 edition.

10. 03/12/1981 - Security door lock system • The use of an electronic device that must be pressed before the panic bar can be activated violates the intent of 29 CFR 1910.36(b)(4). Employers utilizing such a system are cited. • Employees trying to evacuate a smoke filled room may not be able to locate the electronic device and would be trapped at the exit door. • Depression of the panic bar must open the exit without any prior action. Relays which signal a security monitor of the occurrence and which do not inhibit exiting are permitted.

11. Exit Discharge Offices Storage Exit access Discharge Exit Fabricating shop 1910.36(c)(1) Exit Discharge • Each exit discharge must lead directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside

12. 1910.36(d) Maintenance • Every required exit, approach thereto, and way of travel from the exit into the street or open space, shall be continuously maintained free of all obstructions or impediments to full instant use in the case of fire or other emergency.

13. 1910.36(e)(1) A side-hinged exit door must be used • A side-hinged door must be used to connect any room to an exit route • Must swing out in the direction of exit travel if the room is designed to be occupied by more than 50 people or if the room is a high hazard area

14. 1910.36(f) The capacity of an exit route must be adequate • Exit routes must support the maximum permitted occupant load for each floor served See factors for occupant load and capacity in NFPA Life Safety Code - Chapter 7

15. 1910.36(f) The capacity of an exit route must be adequate • The capacity of an exit route may not decrease in the direction of exit route travel to the exit discharge

16. 7-½ ft. 6 ft.- 8 in. 1910.36(g) Exit minimum height and width requirements • The ceiling at least seven feet six inches high • Any projection from the ceiling not lower than six feet eight inches • An exit access must be at least 28 inches wide at all points

17. 1910.36(g) Exit minimum height and width requirements • Objects that project into the exit route must not reduce the width of the exit route to less than the minimum width requirements for exit routes

18. 1910.37(a) The danger to employees must be minimized • Exit routes must be kept free of explosive or highly flammable furnishings or other decorations

19. 1910.37(a)(3) The danger to employees must be minimized • Exit routes free and unobstructed • No materials or equipment may be placed, within the exit route • The exit access must not go through a room that can be locked

20. 1910.37(b) Lighting and marking must be adequate and appropriate • Exit routes adequately lighted • Clearly visible and marked by a sign reading "Exit" • Free of decorations or signs that obscure the visibility of the exit route door

21. 1910.37(b) Lighting and marking must be adequate and appropriate • (4)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 of travel to the nearest exit • Additionally, the line-of-sight to an exit sign must clearly be visible at all times Way to exit is not apparent

22. 1910.37(b) Lighting and marking must be adequate and appropriate • (5)Each doorway or passage along an exit access that could be mistaken for an exit must be marked "Not an Exit" or similar designation, or be identified by a sign indicating its actual use (e.g., closet)

23. 1910.37(b) Lighting and marking must be adequate and appropriate • (6) 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 (7) The word "Exit" in plainly legible letters not less than six inches Letters 3/4 inch thick

24. 1910.37(d) Exit routes must be maintained during construction, repairs, or alterations • (1) 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

25. 1910.37(d) Exit routes must be maintained during construction, repairs, or alterations • (3) Employees must not be exposed to hazards of flammable or explosive substances or equipment used during construction, repairs, or alterations, that are beyond the normal permissible conditions in the workplace, or that would impede exiting the workplace

26. 1910.38 Emergency action plans (EAP) • (b) An emergency action plan must be in writing, kept in the workplace, and available to employees • However, an employer with 10 or fewer employees may communicate the plan orally to employees

27. 1910.38(c) Minimum elements of an emergency action plan • (1) Procedures for reporting a fire or other emergency • (2) Procedures for emergency evacuation, including type of evacuation and exit route assignments

28. 1910.38(c) Minimum elements of an emergency action plan • (3) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate • (4) Procedures to account for all employees after evacuation

29. 1910.38(c) Minimum elements of an emergency action plan • (5) Procedures to be followed by employees performing rescue or medical duties

30. 1910.38(c) Minimum elements of an emergency action plan • (6) The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan Contacts ________ ________ ________

31. 1910.38(d) Employee alarm system • An employer must have and maintain an employee alarm system • The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in § 1910.165

32. 12/16/1992 - Alarm systems for employee evacuation and/or response • The complexity and sophistication of the alarm system depends on the number and size of operations and the associated degree of hazard for a given facility. • A small, single-process plant may only require a simple siren to call for evacuations. • In a larger more complex facility, where multiple contingent responses or multiple contingent evacuation routes may be required of employees, the alarm system should convey clearly the information necessary to allow employees to respond or evacuate.

33. 1910.38(e) Training • An employer must designate and train employees to assist in a safe and orderly evacuation of other employees EAP

34. EAP Change 1910.38(f) Review of emergency action plan • An employer must review the emergency action plan with each employee covered by the plan: • When the plan is developed or the employee is assigned initially to a job • When the employee's responsibilities under the plan change; and • When the plan is changed

35. Our fire plan calls for …. 1st Annual Convention of Employers with fewer than ten employees 1910.39(b) Written and oral fire prevention plans • Must be in writing, • Be kept in the workplace, and • Be made available to employees for review • Employer with 10 or fewer employees may communicate the plan orally to employees

36. 1910.39(c)(1) Minimum elements of a fire prevention plan • A fire prevention plan must include: • A list of all major fire hazards • proper handling and storage procedures for hazardous materials • potential ignition sources and their control • type of fire protection equipment necessary

37. Cans of paint left open, not stored or disposed of upon completion of work 1910.39(c) Minimum elements of a fire prevention plan • (2) Procedures to control accumulations of flammable and combustible waste materials

38. 1910.39(c)(1) Minimum elements of a fire prevention plan • (3) Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials

39. 1910.39(c)(1) Minimum elements of a fire prevention plan • (4) The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires • (5) The name or job title of employees responsible for the control of fuel source hazards