4.4 Exit Routes, Emergency Action Plans & Fire Protection (29 CFR 1910.34-39)

4.4 Exit Routes, Emergency Action Plans & Fire Protection (29 CFR 1910.34-39)

Introduction to Emergency Egress and Fire Safety

Subpart E (Exit Routes and Emergency Action Plans) and Subpart L (Fire Protection) of 29 CFR 1910 contain essential regulations designed to protect workers during fires and other workplace emergencies. This requires establishing clear exit routes, maintaining written emergency response plans, and providing appropriate fire suppression equipment, such as portable fire extinguishers.

Emergency Action Plans (EAP) (29 CFR 1910.38)

Under 29 CFR 1910.38, an Emergency Action Plan (EAP) organizes actions during workplace emergencies:

• Written Plan Requirement: The EAP must be in writing, kept in the workplace, and made available to employees for review.
• The 10-or-Fewer Exception: An employer with 10 or fewer employees is not required to maintain a written EAP; instead, they may communicate the plan orally to employees.
• Minimum Elements of an EAP:
  1. Procedures for reporting a fire or other emergency (e.g., pulling alarms, calling 911).
  2. Procedures for emergency evacuation, including type of evacuation and exit route assignments.
  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 has been completed.
  5. Procedures to be followed by employees performing rescue or medical duties.
  6. The name or job title of every employee who can be contacted for further information or explanation of duties under the plan.
• Employee Training: Employers must train employees when the plan is developed or revised.

Exit Route Standards (29 CFR 1910.36-37)

An exit route is a continuous and unobstructed path of exit travel from any point within a workplace to a place of safety. It consists of three parts: the exit access, the exit, and the exit discharge. OSHA enforces strict design and maintenance rules for exit routes:

• Must be Unlocked (29 CFR 1910.36(d)): Employees must be able to open an exit route door from the inside at all times without keys, tools, or special knowledge. Panic hardware or crash bars that open with simple pressure are standard.
• Must be Unobstructed (29 CFR 1910.37(a)): No equipment or locked doors may block exit routes. Exit routes must not lead through restrooms or storerooms.
• Must be Marked (29 CFR 1910.37(b)): Each exit must be clearly visible and marked by a sign reading 'EXIT' in plainly legible letters. Exit signs must be illuminated, with letters at least 6 inches (15.2 cm) high and principal strokes of letters not less than 3/4 inch (1.9 cm) wide.
• Mistaken Exits: Any door, passage, or stairway that is not an exit but could be mistaken for one must be marked 'Not an Exit' or labeled with its actual character (e.g., 'To Basement' or 'Storeroom').
• Adequate Capacity: The width of exit routes must be sufficient to support the occupant load. The minimum width of an exit route must be at least 28 inches (71.1 cm) at all points, with a minimum ceiling height of 7 feet 6 inches.

Fire Chemistry and Classes of Fire

Fires are classified by fuel type, which determines the correct extinguishing agent.

Portable Fire Extinguishers (29 CFR 1910.157)

When employers choose to provide portable fire extinguishers for employee use, they must comply with selection, distribution, and maintenance requirements:

• Extinguisher Distribution (Travel Distances):
  • Class A: Travel distance to any extinguisher must not exceed 75 feet (22.9 m).
  • Class B: Travel distance must not exceed 50 feet (15.2 m).
  • Class C: Distributed based on the Class A or B hazard it accompanies.
  • Class D: Travel distance must not exceed 75 feet (22.9 m).
  • Class K: Travel distance must not exceed 30 feet (9.1 m).
• The PASS Method for Operation:
  • P - Pull: Pull the pin.
  • A - Aim: Aim at the base of the fire.
  • S - Squeeze: Squeeze the handle.
  • S - Sweep: Sweep from side to side.
• Inspection and Maintenance Requirements:
  • Monthly Visual Inspections: Employers must visually inspect extinguishers monthly to ensure they are in their designated places, fully charged, undamaged, and have intact seals.
  • Annual Maintenance Checks: Extinguishers must undergo a certified annual maintenance check. The date must be recorded on a tag attached to the extinguisher.
  • Hydrostatic Testing: Extinguishers must undergo hydrostatic testing every 5 or 12 years (depending on the type of shell) to verify pressure integrity. For example, dry chemical extinguishers with stainless steel or aluminum shells are tested every 12 years; carbon dioxide and wet chemical extinguishers are tested every 5 years.
• Training: Employees must be trained on extinguisher use and the hazards of incipient-stage firefighting upon initial hire and at least annually thereafter.