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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

April 27, 2000

Mr. Gregory W. Faeth
Safety Consulting & Training Services
PO Box 1718
Fairfield, IA 52556

Dear Mr. Faeth:

Thank you for your December 28, 1999 to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs. Please be aware that this response may not be applicable to any scenario not delineated within your original correspondence. You had specific questions regarding Fixed Industrial Stairs, 29 CFR §1910.24, and the redesignation of the Access to Employee Exposure and Medical Records Standard, 29 CFR §1910.1020. Your questions and our reply follow.

Question #1: The OSHA [exit route] requirements, [§1910.36(g)(2)], state that the minimum width of any way of exit access shall in no case be less than 28 inches and the OSHA stair requirement, §1910.24(d), requires a minimum stair width of 22 inches. Is an employer out of compliance with this [exit route] standard if the stairs are 22 inches in width?

Reply: Yes, if the stair is an [exit route] component (the exit access, the exit itself, or exit discharge). All stairs, and other approved [exit route] components, must meet the Subpart E, [Exit Routes] standards.

Furthermore, in order to afford all occupants convenient facilitates for escape, the capacity of an [exit route] (i.e., stair) for any occupied space must be appropriate to the individual building or structure with due regard to the character of the occupancy; the number of persons exposed; the fire protection available; and the height and type of construction of the building or structure. [See paragraph 1910.36(b)(3).] The minimum width permitted for a passageway used as an exit access is, according to [§1910.37(g)(2)], 28 inches; however, most occupancies require additional width based upon the capacity of [exit route] requirements.

The 22 inch stair width requirement applies to both interior and exterior, fixed industrial stairs (i.e., around machinery, tanks, and other equipment; to and from floors, platforms, or pits) when they are used as described in the application paragraphs 1910.24(a) and (b). Where these requirements overlap, the [Exit Routes] requirements would apply.

Question #2: Why did OSHA move §1910.20 to §1910.1020 without updating other 1910 standard references to §1910.1020? There are many references to §1910.20 and the only corrected reference is in the newer Respiratory Protection, §1910.134, Standard. For example, paragraph 1910.120(f)(8)(i) incorrectly directs a reader to §1910.20 instead of §1910.1020.

Reply: In redesignating §1910.20 as §1910.1020, OSHA has simply moved the standard from Subpart C to Subpart Z of the Part 1910 - Occupational Safety and Health Standards. We have not changed or modified the standard language. Your observation correctly identifies OSHA's omission to change the §1910.20 reference language. Our [Directorate of Standards and Guidance] is currently working on a correction notice to rectify this inconsistency. This notice should be published in the Federal Register and become effective this year.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that the enforcement guidance contained in this response represents the views of OSHA at the time the letter was written based on the facts of an individual case, question, or scenario and is subject to periodic review and clarification, amplification, or correction. It could also be affected by subsequent rulemaking; past interpretations may no longer be applicable. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at If you have any further questions, please feel free to contact the [Office of General Industry Enforcement] at (202) 693-1850.


Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 2/4/2004]

1 The source for the performance-oriented standard is the National Fire Protection Association Life Safety Code (NFPA 101-1970); it is current OSHA's policy to use this consensus standard as a reference source for clarification purposes. In the past, OSHA has used the Life Safety Code (the Code) as an aid in interpreting Subpart E and we intend to continue to rely on the NFPA Life Safety Code (NFPA 101-2000) and other consensus standards as guidance in implementing performance-oriented requirements. [Back to text]

[This document was edited on 02/05/2004 to strike information that no longer reflects current OSHA policy. 29 CFR 1910 Subpart E was revised on November 7, 2002 and incorporates compliance with NFPA 101-2000 at 1910.35.]