Requirements for exit signs and emergency lighting in buildings are governed by numerous regulatory agencies, including OSHA (Occupational Safety and Health Administration), JAHCO (Joint Commission on Accreditation of Healthcare Organizations), the NFPA (National Fire Protection Association), the International FireCode, and the International Building Code. In addition to what is required by these agencies, employers must also comply with any requirements given by their authority having jurisdiction (AHJ). The local AHJ is the one responsible for enforcing fire and building codes. Larger cities like New York and Chicago sometimes have unique rules for exit signage and emergency lighting in buildings. An employer who is not sure who to reach out to for these regulations should start with their local inspector or a fire marshal.
OSHA has defined”exit route” under Code 29 of CFR 1910.34(c) as a clear, continuous path of travel from any point within a workplace to a safe place (including refuge areas). All vertical and horizontal areas along this path are included within the exit route. These are the components that comprise an exit route:
• Exit access – this is that part of an exit route that leads to an exit. For instance, a corridor leading to a two-hour fire-resistance-rated enclosed stairway.
•Exit – this is that part of an exit route separated from other areas to offer a protected path to the exit discharge. For instance, a two-hour fire-resistance-rated enclosed stairway leading from the fifth floor of a building to the outside.
•Exit discharge – this is that part of the exit route that leads directly outside, or to a refuge area or space with access to outside the building. An example would be a door at the end of a stairwell leading outside.
1910.37(b) covers the requirements set forth by OSHA for lighting and marking of exit routes. Stated therein is that each exit route must be lighted enough so that an employee with typical vision can see along it. Additionally, each exit must be clearly visible and marked by a sign that says “Exit”. Also found therein are these requirements:
• In the exit route, doors must be free of decorations or signs that obscure their visibility.
• If the direction of travel to the exit is not obvious, it is necessary to post signs indicating the travel direction. The line-of-sight to an exit sign must also be constantly visible.
• Every doorway or passage found along an exit access that could be mistaken for an exit must be marked “Not an Exit” or else by a sign indicating its actual use.
• Each exit sign must be lit up to 54 lux and be distinctive in color. Self-luminous or electroluminescent signs are permitted provided that they have a luminance surface value of at least 0.6 foot-lamberts.
• All exit signs must have the word “Exit” in readable letters at least six inches high, with the letters’ principal strokes at least 3/4 inches wide.
Under 1910.35, OSHA mentions that if the emergency exit requirements of the NFPA are followed, they are also in compliance with OSHA. Those of the International Code Council and the International Fire Code also are in accordance with OSHA’s requirements.
Exit Sign Requirements from NFPA
The 2015 edition of NFPA 101, Life Safety Code, section 7.10 provides additional guidance on exit signs. Contained within are additional details concerning placement, visibility, and acceptable methods of illumination for exit signs. The requirements for placement state that any new exit signs must be located in such a way that there is no area in the exit access corridor in excess of 100 ft or of the sign’s rated viewing distance (whichever is less) from the nearest sign. If the direction one must travel to get to the exit is not obvious, the exit signs must have directional indicators.
The NFPA also states, regarding visibility, that every exit sign must be of a size, color, and design as to be readily visible and contrast to the background on which it is placed. There must be no decorations impairing the sign’s visibility and no other brightly lit sign that is not an exit sign, which could distract from the exit sign’s ability to be seen.
The Life Safety Code offers many extra details regarding the illumination of exit signs and distinguishes between externally illuminated signs and internally illuminated signs. In section 188.8.131.52, it is stated that all exit signs must be lit up by a dependable light source and must be readable in both normal circumstances and when the building is in an emergency lighting mode.