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Means of Egress

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wbd

Electrical
May 17, 2001
658
Hello,
OSHA 1910 Subpart E - Means of Egress states in 1910.36 that every building, new or old, designed for human occupancy shall be provided with exits and that the building shall have at least two means of egress.

1. Is there any type of "grandfather" clause for buildings constructed prior to OSHA regulations?
2. What is the definition of "designed for human occupancy"? For example, if an employee works in a building periodically versus a building that is staffed 24/7 by 1 person, are they both considered equal?

Thanks in advance.
wbd
 
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wbd,

OSHA has stated the following in a Letter of Interpretation regading the "two exit" requirement...

"Every building or structure, section, or area thereof of such size, occupancy, and arrangement that the reasonable safety of numbers of occupants may be endangered by the blocking of any single means of egress due to fire or smoke, shall have at least two means of egress remote from each other, so arranged as to minimize any possibility that both may be blocked by any one fire or other emergency conditions."

This paragraph does not automatically require at least two means of egress; a second (or more) means of egress would be required if the area were occupied by a large number of employees, or if hazardous processes were being carried out, or for similar reasons. We suggest you ascertain if local building codes require additional means of egress.

I know of no granfather clause for this requirement.

Hope this helps.

Bryan Haywood
 
You might want to check NFPA 101 Life Safety Code. For Class II occupancy they recommend that there be two doors for every location as long as it is greater than 200 square feet. There maybe something there more specific to what you are looking for.
 
You could check your local building code or fire prevention code. Such codes often have "grandfathering" provisions.
 
Hello all,

OSHA does not "grandfather" anything so you ahve to meet the regulation. However, a front and back door in a building may meet thisrequirement.

The answer to your second question is no. For example a single exit route can be used in some cases as outlined in 1910.36 (b)

"A single exit route. A single exit route is permitted where the number of employees, the size of the building, its occupancy, or the arrangement of the workplace is such that all employees would be able to evacuate safely during an emergency.

Note to paragraph 1910.36(b): For assistance in determining the number of exit routes necessary for your workplace, consult NFPA 101-2000, Life Safety Code."
 
After 7 years, OSHA has revised their exit regulations in Subpart E of the 1910 standards. New federal regulations were published in Nov. 7, 2002 that became effective on Dec. 7, 2002 for changes in 29 CFR 1910.36, Means of Egress.
See:

Extracts provided below:

1910.36(b)
The number of exit routes must be adequate.
1910.36(b)(1)
Two exit routes. At least two exit routes must be available in a workplace to permit prompt evacuation of employees and other building occupants during an emergency, except as allowed in paragraph (b)(3) of this section. The 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.
..1910.36(b)(2)

1910.36(b)(2)
More than two exit routes. 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.
1910.36(b)(3)
A single exit route. A single exit route is permitted where the number of employees, the size of the building, its occupancy, or the arrangement of the workplace is such that all employees would be able to evacuate safely during an emergency.

Note to paragraph 1910.36(b): For assistance in determining the number of exit routes necessary for your workplace, consult NFPA 101-2000, Life Safety Code.

"Grandfather clause" is not recognized by the U.S. federal government vs the private sector recognizes the date the building was constructed should match the year of the code.

JOHN HEYWOOD, P.E.,CSP
SENIOR SAFETY ENGINEER
 
THERE ARE EXCEPTIONS TO TWO MEANS OF EGRESS. IT ALL DEPENDS ON OCCUPANT LOAD, BUILDING CONSTRUCTION, OPERATIONS.
 
To: Wbd
From: JH

11-12-2003

1. There is no "grandfather clause" granted in the OSHA
General Industry Regulations.

2. As read in the OSHA General Industry Regulations whether there was one person or more, two exits must be provided for each building.

JOHN HEYWOOD, P.E., CSP
SENIOR SAFETY ENGINEER
Saint Louis, Missouri 63125
 
A TYPICAL EXCEPTION IS A PLACE OF ASSEMBLY WHERE OCCUPANT LOAD IS LESS THAN 50 AND PATH OF EGRESS TO OUTSIDE EXIT IS IF I REMEMBER CORRECTLY IS 35'.
 
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