- Standard Number:1910.37(q)(6)1910.37(q)(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.
February 1, 1991
Mr. Sanford B. White
110 West Lancaster Avenue
Wayne, Pennsylvania 19087
Dear Mr. White:
Thank you for your inquiry of May 29, 1990, concerning the self luminous and electroluminescent exit sign products manufactured by your company. You inquired if your products meet the Occupational Safety and Health Administration (OSHA) requirements. We apologize for the delay in our response.
OSHA standards, specifically with respect to illumination of exit signs, are contained in 29 CFR 1910.37(q)(6) and (q)(7). These standards require the exit signs to be readily visible during employee occupancy of an establishment or a building. The OSHA standard at 1910.37(q)(6) requires the signs to be illuminated with a reliable light source giving a value of 5 footcandles on the illuminated surface, and the standard at 1910.37(q)(7) requires that internally illuminated exit signs be provided in all occupancies where reduction of normal illumination is permitted.
The information you submitted indicates that your products meet all the requirements of the National Fire Protection Association (NFPA) 101, Code for Safety to Life. You also indicated in your letter that your products are approved by Building Officials Code Administration (BOCA), Southern Building Code Congress International (SBCCI), and International Conference of Building Officials (ICBO).
Under our de minimis violations policy (copy enclosed), if an employer complies with a latest industry consensus standard such as NFPA 101 (to correct a hazardous condition), which provides equal or greater employee protection as that of an OSHA standard for a similar hazardous condition, then that employer is considered to be in compliance with the OSHA requirements. Based upon this policy, we determined that your self-luminous and electroluminescent exit sign products will meet OSHA requirements if installed and maintained in a manner recommended by your company. You should note, however, that during employee occupancy of the buildings, if the illumination on the surface of the exit signs is not maintained at or above 5 footcandles, then the employer who is not maintaining such levels on the surface of the exit signs will be in violation of the OSHA standard at 1910.37(q)(6).
You must be aware that OSHA neither approves nor endorses any product, since the product may be misapplied during its installation or during its maintenance. Therefore, this letter should not be treated as a letter of approval.
If we may be of further assistance, please contact us again. Thank you for your interest in safety and health.
Patricia K. Clark, Director
Directorate of Compliance Programs