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 15, 1993

Mr. Tony Bolar-Softich
Manager, Safety National Energy
Production Corporation
18578 N.E. 67th Court
P.O. Box 747
Redmond, Washington 98052

Dear Mr. Bolar-Softich:

This is a further response to your letters of May 12 and October 26, and to the November 2, telephone conversation with Mr. Dillard of my staff, in which you requested an interpretation of the Occupational Safety and Health Administration's (OSHA) standard, [29 CFR 1910.36, Design and construction requirements for exit routes], as it relates to the widths of doorways into electrical equipment enclosures that are twenty-seven and 5/8 inches (70.2 cm) wide. We apologize for the delay in our response.

We reviewed the information provided and determined that our [1910.36] standard does not apply to your situation. Even if [1910.36] did apply to the situation, the deficit of 3/8 inch (0.9 cm) in width would be considered a de minimis violation having no adverse impact on safety and health of employees.

Since the employer has a general duty under the Occupational Safety and Health Act to provide to employees a place of employment free of recognized hazards likely to cause serious harm, every effort should be made to ensure that employees can exit the electrical equipment enclosures safely in the event of an emergency.

If we can be of further assistance, please feel free to contact [the Office of General Industry Enforcement at (202) 693-1850].


Raymond E. Donnelly, Director
[Directorate of Enforcement Programs]

[Corrected 2/4/2004]