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OSHA exit door requirements

17th July 2023

Image of a persons legs as they walk through a fire exit door

Fire exits are a fixture many of us are so familiar with that we hardly pay them any attention. And yet many public places face fines for blocked fire exits every day. So, in this piece we take a look at the specifics around OSHA exit door requirements and steps businesses can ensure they are compliant.

The startling fact is that retail as a whole has seen fines of over $5.5 million between October 2021 and September 2022 for failures of compliance with maintenance, safeguards, operational features, design and construction requirements for exit routes.

What is the law regarding fire exits?

OSHA standard 1910.36 defines an exit route as a continuous and unobstructed path of exit travel from any point within a workplace to a place of safety. The law around fire exits places several regulations around each part of the exit route. In order to comply with fire safety regulations each part of the exit route needs to meet a minimum standard.

OSHA defines the parts of an exit route to be the following:

  • The exit access – the part of an exit route leading to an exit
  • The exit – the part of the exit route which provides a protected way to travel to the exit discharge
  • The exit discharge – the part of the exit route which leads outside the building to a street, walkway or other open space with access to the outside.

For the exit discharge, which includes the fire door, there are a number of regulations for workplace fire safety including:

  • Exits must be clearly marked and free from decorations
  • Fire doors must open directly outside, or to an open space with access to the outside
  • Exits must be separated by fire resistant materials
  • Exits must have a self-closing fire door
  • Exit doors must be unlocked

What action should you take if access to a fire exit is blocked?

A blocked fire exit should be cleared as a matter of urgency – valuable time and human lives can be cost should an exit be blocked in an emergency.

Employees should receive documented training in fire safety, including ensuring they understand the Evacuation Action Plan (EAP) and what is expected of them in an emergency. However this can be easy to overlook in the day-to-day working life and busy employees may need reminders of the safety requirements.

A fire exit door obstructed by a trolley and large boxes. Hazard Detection enables businesses to take control of their health and safety, offering continuous monitoring of protected zones and real-time alerts for non-compliance. For businesses looking to take pro-active action to ensure compliance with safety regulations, our Hazard Detection solution monitors protected zones, including all parts of the exit route, recognising obstructions and notifying through in store communication channels that action must be taken to ensure the safety of working conditions.

OSHA is clear that employees have a right to working conditions that do not pose risk of serious harm to them, this includes fire safety and should be taken seriously by businesses.

Employees are able to report their employers, and request OSHA inspect their workplace for hazards should they feel their workplace is unsafe or poses serious hazards in the face of emergencies. Additionally employees have protection from the OSHA Whistleblower Protection Program to ensure that they can report unsafe environments without retaliation from their employer.

Can fire exit doors be locked?

OSHA standard 1910.36(d)(1) is clear that an exit door must be unlocked. Employees must always be able to open the exit route door from the inside, without the need for keys, tools or special knowledge. The ability to open exit doors at any point includes the restriction of use of any device or alarm which can prevent the door opening in an emergency should the device or alarm fail.

There are exceptional circumstances relating to secure facilities. However even in these circumstances it is clear that exit doors can only be locked should there be supervisory personnel on continuous duty, with a clear evacuation plan to safely remove occupants during an emergency.

In short, fire exit doors must not be locked. Locking them can cost time and lives during an emergency and in an OSHA inspection, they can cost businesses thousands of dollars in fines. Serious OSHA violations can cost up to $156,259 per violation.

The role of computer vision in fire safety compliance

Whilst businesses can write detailed Evacuation Action Plans (EAP), perform thorough fire safety risk assessments and train employees on both of these things, what they cannot do is be present all day every day.

The difficulty for head office then, should an OSHA inspection take place or an emergency happen, is ensuring that they are compliant with regulations without dedicated employees in every store during working hours to ensure compliance. Even with a dedicated person to ensure compliance, they cannot always be present. Lunch breaks, bathroom breaks, sickness absence, annual leave – there are a myriad of reasons why it would still be difficult to maintain compliance with a dedicated employee in every store to focus solely on health and safety. That is without considering the cost and challenge of recruiting qualified health and safety professionals to undertake the roles in the first place.

Lady standing beside an evacuation plan and fire alarm completing paperwork. The only way businesses can ensure their fire exits are not locked or blocked is to check them frequently, or deploy technology such as Hazard Detection to alert on an exit being locked or blocked enabling real-time ability to address non-complianceYet the only way to prevent blocked or locked fire exits is to monitor to see if they are blocked or locked in the first place. Recruiting new employees is already a challenge for retailers. Expecting existing employees to take on additional duties of constant monitoring of fire exits is not feasible.

Combining human intelligence and computer vision

SeeChange views AI as a tool that should be utilised alongside human intelligence, combining the benefits of human understanding with computer vision to undertake the tasks it would be unfeasible, unreliable and unfair to expect employees to take on in addition to their existing roles.

Businesses can define their specific challenges, their protected zones can be mapped and the task of monitoring these areas continuously is offloading onto the AI solution. Should an obstruction be detected, the solution notifies via the existing in store communication channels to require employees to remove the obstruction and store it correctly.

The process provides a full audit trail for businesses, and can be used to demonstrate the implementation of a health and safety system with reporting and insights available for every location.


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