On June 17, 2013, in its newsletter “OSHA QuickTakes”, OSHA reported that it has issued a national memorandum on exit routes directing field inspectors to carefully examine whether employers have provided and maintained adequate exit routes from work areas. This comes in response to a massive fire and explosion at a Chinese poultry processing plant on June 4, 2013, in which an estimated 119 employees perished.  Survivors described workers struggling through smoke and flames to reach doors that turned out to be locked or blocked.

The memorandum directs compliance officers to pay particular attention to the following during an OSHA inspection: whether an adequate number of exit routes are provided, that the exit routes are free and unobstructed, and that exit doors are not locked.     

Employers can take the following internal steps to ensure the safety of their employees and that they are in compliance:

OSHA has listed the key elements that an employer must have in place to provide safe exit routes in OSHA's Emergency Exit Routes Fact Sheet.  A summary of those elements follows:

First, determine whether you have enough exit routes in the workplace.  These exit routes must permit prompt evacuation of the workplace during an emergency.  The number of exit routes required varies:

  • Normally, a workplace must have at least two exit routes.
  • More than two exit routes are required if the number of employees, size of the building, or arrangement of the workplace will not allow employees to evacuate safely with just two exit routes.
  • In limited circumstances, one exit route may be permitted if it allows employees to evacuate safely during an emergency.

Employers must also ensure that exit routes are free and unobstructed.  Exit routes must be free of:

  • Obstructions such as materials, equipment, locked doors, or dead end corridors.
  • Doors with decorations or signs that obscure the visibility of exit route doors.
  • Objects that could impede access to the exit route during construction, repair or alterations to a workplace.
  • Explosive or highly flammable furnishings or decorations.

Exit routes and doors must be properly labeled and maintained:

  • Install “EXIT” signs in plainly legible letters.
  • Post signs along the paths to exit routes indicating the direction of travel to the nearest exit, if that direction is not immediately apparent.
  • Provide lighting for exit routes adequate for employees with normal vision.
  • Mark doors or passages along paths to exit routes that could be mistaken for an exit “Not an Exit” or with a sign identifying its use (such as “Storage Room”).
  • Exit route doors must be unlocked from the inside and must be free of devices or alarms that could restrict use of the exit route if the device or alarm fails.
  • Arrange exit routes so that if one is blocked by fire or smoke the other is available.
  • Arrange exit routes so employees will not have to travel toward a high-hazard area unless the path of travel is effectively shielded from the high-hazard area.
  • Fire-retardant paints or solutions must be renewed often enough to maintain their fire resistant properties.

Finally, employers should confirm that an emergency alarm system is in place to alert employees of an emergency, unless employees can promptly see or smell a fire or other hazard in time to provide adequate warning to them.