Ask the Expert: OSHA Regulations for Exit Routes

In our latest installment of Ask the Expert, brought to you by the team of industry experts at EHS Hero ® , we look at a recent question from a subscriber asking about OSHA regulations for exit routes in an upstairs office. See what the experts had to say.

Q: We have an office that is primarily an open floor plan on the first level. We do have a small upstairs that has a conference room and an office. The main entry and exit to the second floor is a single set of stairs. The windows upstairs are fixed and do not open. What are the OSHA regulations for exit routes in an upstairs office?

The OSHA exit rules do not specifically address the number of exits routes needed for an upstairs office. One stairway serving as an exit from a second-floor office and conference room may be considered sufficient, but it will depend on both OSHA regulations and local building and fire codes. The OSHA regulations at 29 CFR 1910.36 and 29 CFR 1910.37 concerning the design, construction, and operation of exit routes describe how an exit route consists of three parts:

• First, there’s the exit access, the portion of an exit route that leads to an exit
• The second part is the exit, the portion of an exit route that is generally separated from other areas to provide a protected way of travel to the exit discharge, which is the third part of an exit route.
• The third part is the exit discharge, which is 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.

In terms of your scenario, it is likely that some portion of the second floor would be considered the “excess access,” the singular stairway would be the “exit,” and the “exit discharge” would be the portion of the first floor that leads to a door that must lead directly outside of the building. The three parts of the exit route from your second floor must comply with OSHA specifications.

The number of exits routes OSHA requires at a workplace (not taking into account that part of the workplace being exited is on an upper level) “must be adequate” and there must be “at least two” to allow “prompt evacuation.” The OSHA regulation states that “more than two exit routes must be available in a workplace if the number of employees, the size of the building, its occupancy, or the arrangement of the workplace is such that all employees would not be able to evacuate safely during an emergency.” Considering you have employees on a second floor, you would seem to need, at a minimum, at least one exit route upstairs and at least a second one on the ground floor that would allow for the safe and “prompt” evacuation of all employees in an emergency.

Important OSHA design and construction requirements listed for exit routes in the regulations include:

• Exit routes must be located as far away as practical from each other so that if one exit route is blocked by fire or smoke, employees can evacuate using the second exit route. An interpretation of this requirement might necessitate that there be two exit routes from a second floor.
• Exit routes must support the maximum permitted occupant load for each floor served
• Construction materials used to separate an exit from other parts of the workplace must have a one-hour fire resistance-rating if the exit connects three or fewer stories. (Your stairway exit connects two stories.)
• An exit access must be at least 28 inches wide at all points. Where there is only one exit access leading to an exit or exit discharge, the width of the exit and exit discharge must be equal to the width of the exit access.
• The width of an exit route must be sufficient to accommodate the maximum permitted occupant load of each floor served by the exit route. (Information regarding the “Occupant load” is located in NFPA 101-2009, Life Safety Code, and in IFC-2009, International Fire Code.)

In addition to reviewing the OSHA criteria and the NFPA “occupant load” information, state and local building and fire codes require a certain number and type of exit routes depending on a number of factors, including those already discussed. Check with your local building official or municipal or state fire marshal for more information.