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 https://www.osha.gov.

November 27, 1978

L.C. Nicholas, P.E.
The H.K. Ferguson Company
One Erieview Plaza
Cleveland, Ohio 44114

Dear Mr. Nicholas:

This is in response to your recent letter addressed to Mr. Donald Shay and confirms a telephone conversation with a member of my staff, Mr. William Simms, concerning [exit routes]. Your letter was referred to this office for response.

The Occupational Safety and Health Administration's general industry safety and health standards in 29 CFR [1910.36(g)(2)] requires that the minimum width of any way of exit access shall in no case be less than 28 inches. In addition, 29 CFR [1910.37(a)(3)] requires ["Stairs or a ramp must be provided where the exit route is not substantially level"]. Employers unable to meet the [exit route] requirements may because of unusual circumstances apply for a variance in accord with Section 6 of the Act.

A fixed metal ladder meeting the design requirements of 29 CFR 1910.23 would not be acceptable for a second [exit route] (emergency exit).

If I can be of any further assistance, please feel free to contact me.


John K. Barto, Chief
Division of Occupational Safety Programming

[Corrected 2/6/2004 and 8/1/2023]