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Standard Interpretations - Table of Contents
• Standard Number: 1910.36; 1910.36(d)(1)

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.

March 12, 1981

Mr. William B. Reitze
Vice President
Chief Environmental Scientist Health,
Safety and Environment Department
Johns-Manville Sales Corporation
Ken-Caryl Ranch
Denver, Colorado 80217

Dear Mr. Reitze:

This is in response to your correspondence regarding your security door lock system presently installed in the Research and Development building.

29 CFR [1910.36(d)(1)] requires that ["Employees must be able to open an exit route door from the inside at all times without keys, tools, or special knowledge. A device such as a panic bar that locks only from the outside is permitted on exit discharge doors"].

The use of an electronic device that must be pressed before the panic bar can be activated violates the intent of 29 CFR [1910.36(d)(1)]. Employers utilizing such a system are cited. Employees trying to evacuate a smoke filled room may not be able to locate the electronic device and would be trapped at the exit door. Depression of the panic bar must open the exit without any prior action. Relays which signal a security monitor of the occurrence and which do not inhibit exiting are permitted.

It is suggested that Mr. Steve Crown, Branch Manager, Protection Services at Honeywell in Denver, be contacted for assistance in correcting the installation deficiency. Mr. Crown may be reached at telephone number 303-741-3002.

If we may be of further assistance, please call or write.


Bruce Hillenbrand
Deputy Director, Federal
Compliance and State Programs

[Correction 2/6/2004]

Standard Interpretations - Table of Contents

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