Audit, Compliance and Risk Blog

OSHA requirements for workplaces exit routes

Posted by Jon Elliott on Mon, Nov 30, 2020


The Occupational Safety and Health Administration (OSHA) generally requires employers to ensure that employees (and other occupants of your workplace) have adequate and safe routes to leave work areas during fires and similar emergencies. OSHA presents these requirements in its Exit Routes Standard (29 CFR 1910.36 – 1910.37), with tie-ins to its emergency action plan and fire prevention plan standards (29 CFR 1910.38 and 1910.39). The following discussion summarizes the Exit Routes Standard.

How does OSHA define “exit routes” and their elements?

The Exit Routes Standard defines three important elements of these exit routes -- exit access, exit, and exit discharge – and provides technical standards for their construction and maintenance. OSHA defines these terms as follows:

  • Exit access means that portion of an exit route that leads to an exit. An example of an exit access is a corridor on the fifth floor of an office building that leads to a two-hour fire resistance-rated enclosed stairway (the Exit).

  • 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. An example of an exit is a two-hour fire resistance-rated enclosed stairway that leads from the fifth floor of an office building to the outside of the building.

  • 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. An example of an exit discharge is a door at the bottom of a two-hour fire resistance-rated enclosed stairway that discharges to a place of safety outside the building.

How many exit routes are required?

OSHA generally requires that each building or structure provide more than one exit route, to allow prompt evacuation and so that escape will be possible even if any single exit or safeguard is ineffective or unavailable, and no single fire or other emergency is likely to block all exits. Two exit routes may suffice, although some workplaces will require more than two because of the size and/or configuration of the workplace. (OSHA acknowledges that some buildings and structures may be small enough or configured so that a single exit route is sufficient; check applicable fire code standards).

What design and construction requirements apply?

Design and construction requirements to all exit routes:

  • All exit routes must be permanent.

  • Exits must be separated from other parts of the workplace by fire-resistant materials, as follows:

    • Most exits must be separated by materials with a one-hour fire resistance rating.

    • If the exit connects four or more stories, then it must be separated by materials with a two-hour fire resistance rating.

  • Exits may only have openings necessary to allow access from occupied areas and to reach the point of exit discharge.

  • Each opening into an exit must be protected by a rated self-closing fire door that remains closed or closes upon sounding of a fire alarm or employee alarm system.

  • Each exit discharge must lead directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside, which must be large enough to accommodate the building occupants likely to use the route.

  • If exit stairs continue past the exit discharge level, you must interrupt the stairs at that level using doors, partitions or other effective means to channel people to the exit.

  • Exit doors must be unlocked from the inside at all times; panic bars that lock only from the outside are permissible. (Exception: Exit doors may be locked at mental or correctional facilities, if supervisory personnel are continuously on duty and the employer has a plan to move occupants during an emergency.)

  • Exit doors must meet design requirements:

    • doors must be side hinged

    • doors must swing out in the direction of exit travel if the area being evacuated is designed for more than 50 people or is a "high hazard area" (based on materials, processes, and/or contents)

  • Exit route doors must not have any device or alarm that could restrict emergency use if it fails.

  • The exit route must have adequate capacity (measured by "occupant load"; OSHA refers employers to fire codes), and the capacity must not diminish along the route of travel to the exit discharge.

  • The exit route must meet minimum height and width requirements:

    • Ceilings in exit routes must be at least 7.5 feet high; any projection from the ceiling must not reach a point less than 6 feet 8 inches from the floor.

    • Exit access must be "at least 28 inches wide" at all points (Note: Americans with Disabilities Act (ADA) Design Requirements generally require at least 32 inches wide).

    • If a single exit access leads to an exit or exit discharge, the exit and exit discharge must be at least as wide as the access.

    • Exit routes must be wide enough to accommodate the maximum permitted occupant load they serve, and any objects projecting into the route must not reduce its width below this minimum.

  • Outdoor exit routes must:

    • meet the same height and width standards as indoor exit routes

    • incorporate guardrails on unenclosed sides if a fall hazard exists

    • be covered if snow or ice are likely to accumulate, unless the employer demonstrates that any accumulation will be removed before it presents a slipping hazard

    • be reasonably straight

    • have smooth, solid, substantially level walkways

    • not have a dead-end longer than 20 feet

What operations and maintenance requirements apply?

Operations and maintenance requirements to exit routes:

  • Minimize hazards to evacuating employees, including at least the following:

    • maintain exit routes free and unobstructed

    • maintain exit routes free of explosive or highly flammable furnishings or decorations

    • arrange exit routes so employees will not have to travel toward a high hazard area, unless that area is shielded from the exit route

    • exit access must not go through a lockable room, nor lead to a dead-end corridor

    • provide stairs or ramps unless the route is "substantially level"

  • Maintain employee protective safeguards such as sprinklers, alarms, lighting, and doors

  • Provide adequate lighting and markings:

    • each exit route must be adequately lighted so an employee with normal vision can see along the exit route

    • each exit must be clearly visible and marked with a sign reading "EXIT"

    • the word "EXIT" must be in plainly legible letters not less than 6 inches high, with principal strokes of the letters not less than ¾ inch wide

    • each exit sign must be illuminated to a surface value of at least 5 foot-candles (54 lux) and be distinctive in color (self-luminous or electroluminescent signs must have a minimum luminance surface value of 0.06 footlamberts)

    • each exit route door must be free of decorations or signs that obscure its visibility

    • if the appropriate direction of travel is not immediately apparent, provide signs that clearly indicate it; the line of sight to all signs must be clearly visible

    • each doorway or passage along an exit route that is not an exit and could be mistaken for an exit must be clearly marked "NOT AN EXIT" or similar identification

  • Maintain fire retardant paints and solutions to ensure they retain their fire retardant properties.

  • Maintain adequate exit routes during constructions, repairs and alterations

  • Unless employees can "promptly see or smell a fire or other hazard in time to provide adequate warning," install and maintain an operable employee alarm system.

What happens now?

Employers should review their exit routes. This is particularly important if onsite personnel have reconfigured workspaces without explicit attention to these continuing requirements, or if workplaces storage and hygiene requirements are not strictly enforced to ensure that all doors and routes remain accessible and free of ongoing accumulations of materials. 

Self-Assessment Checklist

Does my organization include indoor workplaces where employees may be subject to fires, or other incidents (from chemical releases to workplace violence) that may require evacuations?

If so, has the organization evaluated each workplace for the number, construction, and maintenance of exit routes?

Does the organization have effective policies to train employees to identify and use exit routes, and how to recognize situations that may require evacuation?

Does the organization have effective policies to maintain the structural integrity, identification, and accessibility of all exit routes?

Where Can I Go For More Information?

OSHA 1910 CFR subpart E (Exit Routes and Emergency Planning)

OSHA etool “Design and Construction Requirements for Exit Routes 

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About the Author

Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years. 

Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).

Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).

You may contact Mr. Elliott directly at:

Tags: OSHA, ADA, Exit Routes Standard