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.

June 20, 2018

Michelle L. Bear, AIA, LEED AP BD+C
600 Washington Ave., Suite 1700
St. Louis, MO 63101

Dear Ms. Bear:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA), regarding heights of exit stairways. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any scenario or questions not delineated within your original correspondence. We paraphrased your question, and provided our response, below.

Question: As a part of the renovations and alterations of the Prevedel Federal Building, two new exit stairways were designed and installed to comply with National Fire Protection Association (NFPA) 101, Life Safety Code, as well as the International Fire Code (IFC). If the exit routes comply with one of the two codes (NFPA or IFC), will they comply with OSHA’s exit route requirements at 29 CFR 1910.36(g)(1)?

Reply: Yes, compliance with either NFPA 101 or IFC exit route requirements will meet OSHA’s requirements. 29 CFR 1910.35 states that “OSHA will deem an employer demonstrating compliance with the exit-route provisions of NFPA 101, Life Safety Code, 2009 edition, or the exit-route provisions of the International Fire Code, 2009 edition, to be in compliance with the corresponding requirements in §1910.34, 1910.36, and 1910.37 (incorporated by reference, see §1910.6).”

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 to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,


 

Thomas Galassi, Director
Directorate of Enforcement Programs