OSHA 1910.37: Exit Route Requirements in Plain English

OSHA 29 CFR Part 1910, Subpart E, contains three closely related sections. Section 1910.34 (Coverage and Definitions) defines the terms used in the rest of the subpart. Section 1910.35 (Compliance with Alternate Exit-Route Codes) allows employers to comply by following NFPA 101 instead of the OSHA-specific design rules. Section 1910.36 (Design and Construction Requirements for Exit Routes) sets the basic design — minimum two exit routes, exit-route separation, exit-route arrangement, ceiling height, exit-route width, doors and so on. Section 1910.37 (Maintenance, Safeguards, and Operational Features for Exit Routes) is the operational counterpart: it tells employers how to keep the exit routes usable on a daily basis. Section 1910.38 (Emergency Action Plans) requires the written EAP. Section 1910.39 (Fire Prevention Plans) requires the written fire prevention plan. Together these five sections form the federal baseline for workplace evacuation. OSHA enforces them through inspections triggered by complaints, accidents and programmed industry-specific audits, and citations under 1910.37 are among the most common workplace life-safety violations issued each year.

Section 1910.37(a)(3) requires that exit routes be kept free and unobstructed and that they not be blocked by materials, equipment, locked doors or dead-end corridors. This is the single most-cited 1910.37 provision because storage frequently creeps into corridors, mechanical rooms and exit stairwells over time. The rule applies to the entire exit route — exit access, exit and exit discharge — and to the discharge to the public way outside the building. Section 1910.37(a)(1) further requires that the exit-route doors must be unlocked from the inside, and Section 1910.37(a)(4) requires that safeguards designed to protect employees during an emergency (sprinklers, alarms, fire doors, exit lights) must be maintained in good working order. Section 1910.37(b)(3) explicitly prohibits decorations, furnishings or other objects that would obstruct exits, hide the visibility of the exit signs, or be combustible to the point of acting as an unintended source or path for fire. Periodic walk-throughs of the building looking specifically for blocked exits, locked stair doors and combustible storage are the cheapest and most effective compliance investment an employer can make.

Section 1910.37(b)(1) requires that each exit be clearly visible and marked by a sign reading 'Exit'. Section 1910.37(b)(2) requires that each exit-route door be free of decorations or signs that would obscure the visibility of the exit-route door. Section 1910.37(b)(4) requires that if the direction of travel to the exit or exit discharge is not immediately apparent, signs must be posted along the exit route indicating the direction of travel to the nearest exit and exit discharge — and that any door, passage or stairway that is along an exit route but does not lead to an exit must be marked 'Not an Exit' or with a sign identifying the actual use, such as 'Closet'. Section 1910.37(b)(6) requires that each exit sign be illuminated to a surface value of at least five foot-candles by a reliable light source and be distinctive in color, and Section 1910.37(b)(7) requires that each exit sign have the word 'Exit' in plainly legible letters not less than six inches high, with the principal strokes of the letters in the word 'Exit' not less than 3/4 inch wide. The posted evacuation plan should mirror the sign locations so an occupant matching the plan to the wall sees the same set of EXIT and NOT AN EXIT messages.

Section 1910.37(b)(5) requires that each exit route be adequately lighted so that an employee with normal vision can see along the exit route. While this section does not set a specific foot-candle level (NFPA 101 and the IBC do), OSHA inspectors evaluate it functionally — can an employee see along the path with normal vision under the lighting actually provided. Backup lighting is implicitly required because an exit route that goes dark when the power fails is not adequately lighted. Section 1910.37(c) governs fire retardant paints — when used on doors or surfaces of exit routes, the coatings must be maintained, which in practice means inspecting them periodically and recoating when wear is evident. Section 1910.37(d) addresses exit routes during construction, repairs or alterations: employees may not occupy a workplace under construction unless the required exit routes are provided and maintained, and an alternate exit-route is provided if one is taken out of service for construction. Posted plans must be updated whenever construction phasing changes the available egress.

Section 1910.36 (design) and Section 1910.37 (operation) together cover the physical building, while Section 1910.38 covers the people-side Emergency Action Plan. The design rules in 1910.36 set the minimums: at least two exit routes, exit-route arrangement so that all employees can evacuate, exit-route capacity sufficient for the maximum permitted occupant load, minimum 7 ft 6 in ceiling height, minimum 28-inch clear width at any point in the route, doors that swing outward and connect directly to the exit discharge, and exit discharge that leads to a street, walkway, refuge area or public way. Section 1910.37 takes those minimums and demands they be preserved during operation. Section 1910.38 then layers on the written EAP, the alarm system to notify employees, the procedures for evacuating, the procedures for accounting for employees after the evacuation, the rescue and medical duties, the procedure for reporting emergencies, and the names or titles of employees who can be contacted for more information. A single posted evacuation plan that shows the exits required by 1910.36, marked the way 1910.37 demands and integrated with the EAP roles defined by 1910.38, satisfies the documentation expectation an OSHA inspector arrives with.

OSHA compliance officers evaluate 1910.37 by walking the facility, paying particular attention to: every exit door (is it unlocked from the inside, undamaged, marked with an EXIT sign and free of obstruction); every exit corridor (is it clear, the required width, illuminated, with no combustible decorations); every stairwell (are the doors unlocked from the egress side, the stair clear of storage, handrails intact, illumination on); the exit discharge (does it actually lead to the public way and is it clear of stored material). They look for signs that are dim, broken, missing or pointed in the wrong direction. They look for delayed-egress locks that are not properly documented. They look at the EAP to see if it matches the actual building and check whether employees can describe their assigned roles. They almost always look at the posted evacuation plan if one is posted, comparing it to the actual exits and signage. The most common citation cluster is locked exit doors, blocked exits, unlit exit signs and EAPs that do not match the building, and any of these can result in serious citations and substantial penalties.

Daily compliance with 1910.37 depends on three things: an accurate, up-to-date posted evacuation plan; a routine walk-through that verifies the building still matches the plan; and a documented EAP that reflects current staff assignments. EvacPlan Generator (www.evacplangenerator.com) makes the first piece straightforward — upload a current floor plan, drop in the standard exit, extinguisher and alarm icons, draw the primary and secondary exit routes with arrows toward the exit discharge, generate the MAP KEY automatically, and export a print-ready PDF for every posted location in the building. The tool's two-tier autosave preserves the project so that small layout changes (a relocated copier, a new wall) can be captured in minutes rather than redrawn from scratch. When the facility undergoes a renovation, the same project can be branched into a temporary phase plan that reflects the construction-time exit routes required by 1910.37(d). Pair the posted plan with a quarterly walk-through using a 1910.37-derived checklist and the EAP from 1910.38, and the building is in the strongest possible position for an unannounced OSHA visit.