Why OSHA Applies to Your Exit Routes
Emergency lighting is a critical part of your building's life safety system. In a manufacturing plant or warehouse, OSHA rules apply alongside local fire and building codes.
OSHA's exit route rules are in 29 CFR 1910, Subpart E, "Exit Routes and Emergency Planning." Sections 1910.34 through 1910.39 cover general industry workplaces. Mobile workplaces such as vehicles and vessels are excluded.
What Counts as an Exit Route
OSHA defines an exit route as a continuous and unobstructed path of exit travel from any point in a workplace to a place of safety. It has three parts:
- Exit access: the part of the route that leads to an exit
- Exit: the part that is generally separated from other areas to provide a protected way to the exit discharge
- Exit discharge: the part that leads directly outside, or to a street, walkway, refuge area, public way or open space with access to the outside
Lighting rules apply to the whole route, not just the door.
What 1910.37 Requires for Lighting
Adequate Lighting
Section 1910.37(b) opens with a plain rule: "Lighting and marking must be adequate and appropriate."
Section 1910.37(b)(1) then says: "Each exit route must be adequately lighted so that an employee with normal vision can see along the exit route."
OSHA does not set a foot-candle level for the route itself. The test is whether a worker with normal vision can see along it.
Exit Signs
The exit sign rules are more specific:
- Each exit must be clearly visible and marked by a sign reading "Exit" (1910.37(b)(2))
- If the way to the exit is not obvious, signs must show the direction of travel, and the line of sight to an exit sign must be clearly visible at all times (1910.37(b)(4))
- Doorways that could be mistaken for an exit must be marked "Not an Exit" or labeled with their actual use (1910.37(b)(5))
- Each exit sign must be lit to at least five foot-candles (54 lux) by a reliable light source and be distinctive in color. Self-luminous or electroluminescent signs with at least 0.06 footlamberts are permitted (1910.37(b)(6))
- The word "Exit" must be at least six inches high, with strokes at least three-fourths of an inch wide (1910.37(b)(7))
Safeguards in Working Order
Section 1910.37(a)(4) lists exit lighting among the safeguards that protect employees in an emergency. These safeguards "must be in proper working order at all times."
What 1910.37 Does Not Say
The text of 1910.37 does not use the term "emergency lighting." It does not set a battery duration or a testing schedule.
Those details come from NFPA 101, the Life Safety Code, and from the fire code your city or county enforces. NFPA 101 calls for at least 90 minutes of emergency illumination, a monthly 30-second test and an annual 90-minute test for battery-powered units, with written records.
How OSHA Relates to NFPA 101
Section 1910.35 is titled "Compliance with alternate exit-route codes." It says OSHA will deem an employer in compliance with 1910.34, 1910.36 and 1910.37 if the employer shows compliance with the exit-route provisions of:
- NFPA 101, Life Safety Code, 2009 edition, or
- the International Fire Code, 2009 edition
Note the edition. OSHA's alternative names the 2009 editions, while your local fire marshal may enforce a newer code. In Texas, the State Fire Marshal's Office uses the 2021 edition of NFPA 101 as its standard of inspection, effective September 1, 2023. Austin and San Antonio each adopt the International Fire Code with local amendments.
Ask your AHJ which code and edition apply to your building.
What This Means for Plants and Warehouses
When racking moves, equipment goes in or walls go up, a route that was lit and visible may not be anymore. Check after every layout change.
Things to check:
- Racking, stock or equipment that blocks light or the line of sight to an exit sign. 1910.37(a)(3) also bars placing materials or equipment in the exit route
- Exit signs that are dark, damaged or hidden
- Emergency lights that no longer cover a route after a layout change
- Test records for battery-powered units
How Automated Testing Helps
The ABB Emergi-Lite Nexus Pro system runs monthly 30-second and annual 90-minute tests on a schedule or on demand. Tests can be scheduled around production, with no manual test walk on the floor.
- Defective units trigger push notifications with the issue and the part number needed
- Reports in the ABB cloud cover test results, maintenance history and offline devices
- One dashboard covers many properties
- There are no per-device subscription fees
Key Takeaways
- 1910.37(b)(1) requires each exit route to be adequately lighted so an employee with normal vision can see along it
- Exit signs must be lit to at least five foot-candles or meet the self-luminous alternative
- Exit lighting must be in proper working order at all times
- OSHA does not set an emergency lighting duration or test schedule; NFPA 101 and local fire codes do
- 1910.35 accepts compliance with the 2009 NFPA 101 or 2009 IFC exit-route provisions
LivSafe Solutions is an authorized ABB Emergi-Lite distributor and commissioning provider serving manufacturing and industrial facilities in Austin and San Antonio.