Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

October 1, 1993

Mr. Mark A. Roche
American Brands, Inc.
1700 East Putnam Avenue
Greenwich, Connecticut 06870-0811

Dear Mr. Roche:

This is in response to your letter of June 25, in which you requested a written confirmation from the Occupational Safety and Health Administration (OSHA) on whether an employer who meets the National Fire Protection Association (NFPA) 101, Life Safety Code, is considered in compliance with OSHA's Subpart E-Means of Egress standard, 29 CFR 1910.35 through 1910.38. Additionally, you sought confirmation on whether an employer who meets state building safety codes, such as those of Building Officials and Code Administrators, Inc. (BOCA), is considered in compliance with the aforementioned OSHA standards. Please excuse the delay in our response.

Employers who meet the requirements of NFPA-101 are considered in compliance with 29 CFR 1910, Subpart E. Employer compliance with revised national consensus standards, such as, NFPA-101, which provide equal or greater employee protection to that provided by an earlier version promulgated into OSHA standards, would be acceptable to OSHA. The enclosed pages from OSHA Instruction CPL 2.45B, of June 15, 1992, further explain this policy.

OSHA recognizes state building life safety codes, such as BOCA, to the extent that such codes are in compliance with OSHA standards.

If you have any additional questions, please feel free to contact [the Office of General Industry Compliance Assistance at (202) 693-1850].


Roger A. Clark, Director
Dictorate of Compliance Programs