Standard Interpretations - Table of Contents Standard Interpretations - Table of Contents
• Standard Number: 1910.37; 1910.37(b)(7)

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.


July 18, 1986

Mr. Daniel A. Nastro
Citibank, N.A.
111 Wall Street
New York, New York 10043

Dear Mr. Nastro:

This is in response to your letter of July 1, 1986, concerning exit signs.

The Occupational Safety and Health Administration (OSHA) standard at 29 CFR [1910.37(b)(7)] requires exit signs to be [not less than six inches (15.2 cm) high, with the principal strokes of the letters in the word "Exit" not less than three-fourths of an inch (1.9 cm) wide]. This standard was adopted from NFPA 101-1970, the Life Safety Code.

As you are aware, NFPA 101 was modified by the NFPA in 1973 to include an exception to the size of the lettering. The exception states: "Existing externally illuminated exit signs, having the word "exit" in plainly visible letters not less than 4 1/2 inches high in existing buildings, other than in places of assembly, may be continued in use."

If your facilities are not places of assembly, per NFPA 101-1973, section 4-112 then externally illuminated exit signs would be in compliance with the 1973 and current NFPA Life Safety Code. Such a violation of the OSHA standard is a de minimis violation and is not subject to penalty nor does it require correction. The complete definition of a de minimis violation is enclosed.

If we may be of further assistance, please contact us.

Sincerely,


John B. Miles, Jr., Director
Directorate of Field Operations

Standard Interpretations - Table of Contents Standard Interpretations - Table of Contents