3.4 Exit Routes, Emergency Action Plans (EAPs) & Fire Prevention Plans (1910.34-39)

Subpart E Overview & Regulatory Scope (29 CFR 1910.34)

OSHA's 29 CFR 1910 Subpart E (1910.33 through 1910.39) covers exit routes, Emergency Action Plans (EAPs), and Fire Prevention Plans (FPPs). The primary objective of Subpart E is to ensure that employees can safely and rapidly evacuate workplace buildings during fires, chemical releases, structural emergencies, or other life-threatening events.

Under 29 CFR 1910.34, OSHA defines the scope and fundamental terms governing building evacuation architecture. An exit route is defined as a continuous and unobstructed path of exit travel from any point within a workplace to a safety zone (typically an outdoor open space).

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The Three Components of an Exit Route (29 CFR 1910.34(c))

An exit route consists of three distinct, continuous sections that must remain fully integrated during an emergency:

1. Exit Access: That portion of an exit route that leads to an exit. Example: A corridor, hallway, or aisle leading from an office or shop floor to a fire-rated stairwell door. Travel distance across exit access is regulated based on building occupancy and hazard class.
2. Exit: That portion of an exit route that is separated from other spaces of the building by construction or equipment as required to provide a protected path of travel to the exit discharge. Example: A 2-hour fire-rated enclosed stairwell or fire door enclosure.
3. Exit Discharge: That portion of an exit route that leads directly outdoors or to a street, walkway, refuge area, public way, or open space with access to the outside. Example: A ground-level exterior door or ground discharge ramp leading away from the building exterior.

+-------------------------------------------------------------+
|               THREE COMPONENTS OF AN EXIT ROUTE             |
|                                                             |
|  [ Work Area ]                                              |
|       ||                                                    |
|       ||  <-- 1. EXIT ACCESS (Hallway / Aisle)              |
|       /                                                    |
|  [ Fire Door ]                                              |
|       ||                                                    |
|       ||  <-- 2. EXIT (Fire-Rated Enclosed Stairwell)       |
|       /                                                    |
|  [ Exterior Door ]                                          |
|       ||                                                    |
|       ||  <-- 3. EXIT DISCHARGE (Outdoor Open Space / Street)|
|       /                                                    |
|  [ Safe Assembly Point ]                                    |
+-------------------------------------------------------------+

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Design & Construction Specifications for Exit Routes (29 CFR 1910.36)

29 CFR 1910.36 establishes technical design and construction standards that buildings must meet to guarantee safe occupant egress.

Fire Resistance & Separation

Exits must be separated from other building spaces by fire-resistant materials:

• 1-Hour Fire Rating: Exits connecting 3 or fewer stories must be constructed of materials with at least a 1-hour fire-resistance rating.
• 2-Hour Fire Rating: Exits connecting 4 or more stories must be constructed of materials with at least a 2-hour fire-resistance rating.
• Openings: Opening into exits must be limited to those necessary to provide access from occupied areas, and doors must be self-closing fire doors.

Number of Exit Routes

A workplace building must have at least two exit routes located as remote from each other as possible to minimize the possibility that a single fire or emergency could block both routes. Single exit routes are permitted only in rare small buildings where occupancy and travel distance are so limited that all occupants can evacuate safely.

Door Swing & Locking Hardware Rules (1910.36(e))

• Side-Hinged Doors: Exit doors must be side-hinged.
• Direction of Swing: Exit doors must swing outward in the direction of exit travel if the room or space is occupied by more than 50 persons or contains a high-hazard contents area (e.g., flammable liquid storage rooms).
• Unlocking Mechanism: Exit doors must be openable from the inside without keys, tools, or special knowledge (e.g., panic bars or single-action push handles). No device or alarm may be installed that restricts emergency exit travel from the inside.

Dimensional & Capacity Limits (1910.36(g))

• Minimum Exit Route Width: Exit routes must be at least 28 inches (71.1 cm) wide at all points. Where objects project into the exit route, clear width must not be reduced below 28 inches.
• Minimum Ceiling Height: Exit routes must have a ceiling height of at least 7 feet 6 inches (90 inches / 228.6 cm).
• Headroom Clearance: Any projection from the ceiling (e.g., light fixtures or pipes) must leave a vertical headroom clearance of at least 6 feet 8 inches (80 inches / 203 cm) above the floor.

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Maintenance, Safeguards & Signage (29 CFR 1910.37)

Under 29 CFR 1910.37, exit routes must be continuously maintained free of obstructions and hazards.

Operational Safeguards:

• Unobstructed Path: Exit routes must be kept free of decorations, furnishings, equipment, stored boxes, or trash. No hazardous or highly flammable decorations may be placed near exit access routes.
• No Mirrors or Distractions: Mirrors must not be placed on exit doors, and exit doors must not be concealed by drapes or wall hangings.
• Lighting & Illumination: Exit routes must be adequately illuminated by artificial lighting so that employees with normal vision can see the path of travel.
• Exit Signage: Each exit door must be clearly marked by a sign reading "EXIT". Exit signs must be illuminated to a surface value of at least 5 foot-candles or be self-luminous.
• Sign Lettering: Lettering on exit signs must be at least 6 inches (15.2 cm) high, with principal letter strokes not less than 3/4 inch (1.9 cm) wide.
• Directional Signs: If the direction of travel to an exit is not immediately visible, directional signs (e.g., "EXIT" with an arrow) must be posted along the exit access.
• Non-Exit Door Marking: Any door, passage, or stairway that is neither an exit nor a way of exit access, and that could be mistaken for an exit, must be clearly marked "Not an Exit" or identified by its actual use (e.g., "Storeroom", "Linen Closet").

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Emergency Action Plans (EAPs) (29 CFR 1910.38)

An Emergency Action Plan (EAP) under 29 CFR 1910.38 facilitates organizer actions during workplace emergencies.

Written vs. Oral Plan Threshold

• Employers with 10 or fewer employees: May communicate the plan orally to employees.
• Employers with more than 10 employees: Must have a written EAP, kept in the workplace and available for employee review.

The Six Mandatory Core Elements of an EAP (1910.38(c))

An EAP must include, at a minimum, the following six core elements:

1. Emergency Reporting Procedures: Procedures for reporting a fire or other emergency (e.g., dialing 911, pull stations, internal emergency numbers).
2. Evacuation Procedures & Route Assignments: Emergency escape procedures and emergency escape route assignments (floor plans, designated exit routes).
3. Critical Plant Operations: Procedures to be followed by employees who remain to operate critical plant operations before they evacuate (e.g., shutting down main gas valves, electrical generators, or boilers).
4. Employee Accounting: Procedures to account for all employees after evacuation is completed (headcount procedures at designated assembly points).
5. Rescue & Medical Duties: Rescue and medical duties for designated employees who are trained to perform them.
6. Contact Persons: Names or job titles of persons who can be contacted for further information or explanation of duties under the plan.

Alarm Systems & Training

Employers must maintain an employee alarm system meeting 1910.165 standards. Employers must review the EAP with each employee upon initial assignment, when employee responsibilities change, or when the plan itself changes.

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Fire Prevention Plans (FPPs) (29 CFR 1910.39)

While an EAP focuses on evacuation during an active emergency, a Fire Prevention Plan (FPP) under 29 CFR 1910.39 focuses on preventing fires from starting.

Employee Threshold & Mandatory Elements:

• Written if > 10 employees; oral permitted if 10 or fewer.
• Must detail major workplace fire hazards, proper handling and storage procedures for flammable and combustible materials, potential ignition sources (e.g., welding, electrical machinery) and control procedures.
• Must list fire protection equipment installed to control fire hazards.
• Must identify names or job titles of employees responsible for maintenance of fire protection equipment and control of fuel source hazards.
• Must establish housekeeping procedures for controlling accumulations of flammable and combustible waste materials, and procedures for maintenance of heat-producing equipment.

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Summary Matrix of Subpart E Standards