November 21, 2003

Lee Clarke
Director, Safety and Health Department
125 Barclay Street
New York, NY 10007-2179

Dear Ms. Clarke:

Thank you for your July 22, 2003 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You have a question regarding OSHA's interpretation of building security measures and how they impact the ability of workers to exit a building during an emergency.

Your Question and Comment: Electronically operated turnstile systems requiring coded cards are being installed at lobbies (exit discharge) of city and leased buildings. Furthermore, internal doors (exit route doors) leading to offices and designated fire stairs are also being closely monitored and are being equipped with electronic card access devices. Workers must swipe their identification cards to enter and exit areas. Use of an exit route can be restricted if any of these devices fail. Your question is whether this constitutes obstructed access to an exit.

Answer: Effective December 7, 2002, OSHA revised its standards for means of egress. The purpose of this revision was to rewrite the existing requirements in clearer language so they would be easier to understand by employers, employees, and others who use them. The rules are performance-oriented to the extent possible and more concise than the original, with fewer subparagraphs and fewer cross-references to other OSHA standards.

Furthermore, OSHA evaluated the National Fire Protection Association's Standard 101, Life Safety Code, 2000 Edition (NFPA 101-2009) and concluded that the standard provides comparable safety to OSHA's new Exit Routes Standard. Therefore, pursuant to 29 CFR 1910.35, employers who wish to comply with the NFPA 101-2009, "Access-Controlled Egress Doors" standard (which addresses electronic swipe cards) will also be in compliance with corresponding requirements of OSHA's Exit Route standard.

The 2000 Life Safety Code standard on "Access-Controlled Egress Doors" allows for the doors/turnstiles in question. However, these doors/turnstiles that are part of the means of egress must be equipped with an approved entrance and egress access control system, provided that the following criteria are met:

[(a) A sensor shall be provided on the egress side and arranged to detect an occupant approaching the doors, and the doors shall be arranged to unlock in the direction of egress upon detection of an approaching occupant or loss of power to the sensor.

(b) Loss of power to the part of the access control system that locks the doors shall automatically unlock the doors in the direction of egress.

(c) The doors shall be arranged to unlock in the direction of egress from a manual release device located 40 in. to 48 in. (102 cm to 122 cm) vertically above the floor and within 5 ft (1.5 m) of the secured doors. The manual release device shall be readily accessible and clearly identified by a sign that reads as follows:

PUSH TO EXIT

When operated, the manual release device shall result in direct interruption of power to the lock — independent of the access control system electronics — and the doors shall remain unlocked for not less than 30 seconds.

(d) Activation of the building fire-protective signaling system, if provided, shall automatically unlock the doors in the direction of egress, and the doors shall remain unlocked until the fire-protective signaling system has been manually reset.

(e) Activation of the building automatic sprinkler or fire detection system, if provided, shall automatically unlock the doors in the direction of egress and the doors shall remain unlocked until the fire-protective signaling system has been manually reset.]

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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.

If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director
Directorate of Enforcement Programs

[This document was edited September 2008 to replace incorrectly referenced text of NFPA 101-2003 Edition with the correct referenced text from the NFPA-101 2000 Life Safety code.]

[Corrected 8/1/2023]