- Standard Number:1910.36(b)(4)1910.37(q)(6)
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.
February 27, 1973
REPLY TO ATTN OF: OS
SUBJECT: Clarification of 1910.36(b)(4) and 1910.37(q)(6)
TO: Messrs. Carl Meyers, and John J. Kearney
This is in reply to your memo of September 28, 1972, to Mr. Fred Bishoff.
Item #1 - 1910.36(b)(4)
To quote a portion of this standard: "No lock or fastening device to prevent free escape from the inside of any building SHALL BE INSTALLED except in manual, penal, or corrective institutions where supervisory personnel is continuously on duty and protective provisions are made to remove occupants in case of fire or other emergency."
Q. a) Is the above statement intended to mean that no locking device may be installed on the inside of a door whether the lock is bolted or open?
Concerning Section 1910.36(b)(4), we are recommending a proposed rule making that would amend the subparagraph to permit the installation of locking devices on doors in a means of egress. The following lettered answers conform to your lettered questions pertaining to Section 1910.36(b)(4).
A. a) Currently - Yes. See above statement concerning a proposed modification.
Q. b) Are panic type hardware the only permissible locking devices? What types of locking devices are allowable inside of a fire exit door?
A. b) No. The latch of a door in a means of egress can also be retracted by knob, handle or other simple type of releasing device, the method of operation of which is obvious even in darkness.
Q. c) During evening hours, when the plant is locked, and a watchman makes his rounds, is it a violation to keep the exit doors locked while he is making his rounds?
A. c) (First line of text unreadable.) in a means of egress must be maintained openable from the side from which egress is to be made without the use of a key. Such doors may be locked against opening from the opposite direction.
Q. d) Do hangers on the door jamb, to accommodate a bar across the door, constitute a locking device? Is this a violation?
A. d) Yes. Currently the installation of the hangers would be a violation but would be permitted by the mentioned proposed rule making.
Q. e) Does installation of dead-locks on the inside of an exit door constitute a violation?
A. e) If the "dead-locks" can be actuated to prevent opening from the side from which egress is to be made, they would currently be in violation. Such locks would be permitted by the mentioned proposed rule making.
Item 2 - 1910.37(q)(6)
"Every exit sign shall be suitably illuminated by a reliable light source giving a value of not less than five foot candles on the illuminated surface. Artificial lights giving illumination to exit signs other than the internally illuminated types, ect."
Q. a) Does the above portion of the standard mean that every exit light must have its own source of reliable illumination? Does each exit light require its own bulb? Must the source of power be obtained from the high side of the fuse?
A. a) The first question is unclear since the term, "exit light" is used, whereas the standard uses the term "exit sign" of the externally and internally illuminated types. In answering the second question, we will assume that, in this instance, where the term "exit light" is used: "internally illuminated exit sign" is intended. With the mentioned change, the answer is "yes"; however, such signs normally have two bulbs. In order to answer the third question, we need further information on the circuit arrangement(s) contemplated by the question.
Q. b) Can this standard be interpreted to mean that as long as there is a reliable light source in the room, hall, vestibule or enclosure that provides 5 C.P. of illuminated surface on the exit sign, as read from our light meter, these conditions will meet the requirements of this standard?
A. b) Yes; however, the location indicating light is still required. The location indicating light must have the required 25 square inch area of red or other designating color translucent material visible from the side of approach.
c/Gerard F. Scannell
Office of Standards