Exit Routes and Emergency Action Plans

Exit Routes and Emergency Action Plans (29 CFR 1910.33 to 1910.39) are the OSHA general industry rules that make sure employees can get out of a building quickly and safely in a fire or other emergency. They cover how exit routes are designed, built and maintained, and how employers plan for, communicate and practice an emergency response.

These rules apply to nearly every general industry workplace, and blocked exits or outdated plans are easy for an inspector to spot.

What Are the Exit Route and Emergency Action Plan Rules?

The requirements make up Subpart E, Exit Routes and Emergency Planning, of 29 CFR Part 1910:

• 1910.34 Coverage and definitions
• 1910.35 Compliance with alternate exit-route codes
• 1910.36 Design and construction requirements for exit routes
• 1910.37 Maintenance, safeguards and operational features for exit routes
• 1910.38 Emergency action plans
• 1910.39 Fire prevention plans

An exit route is a continuous and unobstructed path of exit travel from any point in a workplace to a place of safety. It has three parts: the exit access, which leads to an exit; the exit, which is separated from other areas to provide protected travel to the exit discharge; and the exit discharge, which leads directly outside or to a street, walkway, refuge area or other open space with access to the outside.

An emergency action plan (EAP) is the employer's written plan for what employees do in an emergency, such as a fire, chemical release or severe weather. Read more in our glossary entry on the emergency action plan.

Who Must Comply?

The exit route rules in 1910.34 through 1910.37 apply to all general industry workplaces, except mobile workplaces such as vehicles and vessels. Under 1910.35, an employer that complies with the exit route provisions of NFPA 101, Life Safety Code (2009 edition), or the International Fire Code (2009 edition) is treated as complying with the corresponding OSHA requirements.

The EAP and fire prevention plan sections work differently. Under 1910.38(a) and 1910.39(a), an employer must have these plans when another OSHA standard in Part 1910 requires one. Examples include Portable Fire Extinguishers (1910.157), where an employer that has everyone evacuate rather than fight fires needs an EAP and fire prevention plan to use the exemption, and Process Safety Management (1910.119). Many employers adopt an EAP as a best practice even when no standard requires it.

State Plan states must have equivalent or stricter rules, and local fire and building codes often add requirements.

Key Requirements for Exit Routes

Design and construction, 1910.36

• Exit routes must be a permanent part of the workplace.
• An exit must be separated by fire-resistant materials: a 1-hour rating if it connects three or fewer stories, and a 2-hour rating if it connects four or more.
• Openings into an exit must be limited and protected by self-closing fire doors.
• At least two exit routes are normally required, located as far apart as practical, so employees can evacuate if one is blocked. A single route is allowed only when the building size, occupancy and arrangement let all employees evacuate safely. More than two may be needed for safe evacuation.
• Exit doors must be unlocked from the inside so employees can open them without keys, tools or special knowledge. Limited exceptions apply to mental, penal or correctional facilities.
• Exit route doors must be side-hinged. They must swing out in the direction of exit travel if the room is designed for more than 50 people or is a high hazard area.
• Ceilings must be at least 7 feet 6 inches high, with no projection lower than 6 feet 8 inches. The exit access must be at least 28 inches wide at all points, and the route must support the maximum permitted occupant load without narrowing toward the exit discharge.
• Outdoor exit routes need guardrails where there is a fall hazard and no dead ends longer than 20 feet.

Maintenance and safeguards, 1910.37

• Keep exit routes free of highly flammable furnishings and decorations.
• Keep exit routes unobstructed. No materials or equipment, even temporarily. Routes must not pass through lockable rooms or lead into dead-end corridors.
• Keep fire protection safeguards, such as sprinklers, alarms, fire doors and exit lighting, in proper working order at all times.
• Light exit routes adequately, and mark each exit with an "Exit" sign. Signs must be illuminated to at least 5 foot-candles, or be self-luminous or electroluminescent with a minimum luminance of 0.06 footlamberts, with letters at least 6 inches high and strokes at least three-quarters of an inch wide.
• Post directional signs where the way to the nearest exit is not immediately apparent, and mark doors that could be mistaken for exits "Not an Exit" or with a sign showing their actual use.
• Install and maintain an operable employee alarm system with a distinctive signal, unless employees can promptly see or smell a fire and warn others. The alarm must comply with 1910.165.

Emergency Action Plan Requirements, 1910.38

The EAP must be in writing, kept in the workplace and available for employees to review. An employer with 10 or fewer employees may communicate the plan orally. At a minimum, the plan must include:

1. Procedures for reporting a fire or other emergency
2. Procedures for emergency evacuation, including the type of evacuation and exit route assignments
3. Procedures for employees who stay behind to operate critical plant operations before they evacuate
4. Procedures to account for all employees after evacuation
5. Procedures for employees performing rescue or medical duties
6. The name or job title of every employee who can be contacted for more information about the plan

The employer must have an employee alarm system that uses a distinctive signal for each purpose and complies with 1910.165. It must also designate and train employees to assist in a safe and orderly evacuation.

Plan review with employees

The employer must review the EAP with each employee covered by it when the plan is developed or the employee is assigned initially to a job, when the employee's responsibilities under the plan change, and when the plan is changed. The standard does not set a fixed drill frequency, but regular drills are the most practical way to show the plan works.

Fire prevention plans, 1910.39

When required, the fire prevention plan must also be written, with the same oral option for 10 or fewer employees. It must list major fire hazards, proper handling and storage of hazardous materials, potential ignition sources and their control, and the fire protection equipment needed; describe procedures to control flammable and combustible waste and to maintain safeguards on heat-producing equipment; and name the people responsible for that equipment and for controlling fuel source hazards. Employees must be informed of the fire hazards they are exposed to when first assigned to a job.

Common Violations and Penalties

• Blocked or locked exits, often from stored pallets, carts or inventory, or doors chained after hours.
• Missing or dark exit signs, and no "Not an Exit" marking on doors that lead to storage rooms or dead ends.
• Written plans that are out of date, with former employees listed as contacts or no accounting procedure.
• No review with new hires or after the plan or someone's role changes.
• No designated evacuation assistants, or assistants who were never trained.

As of 2026, OSHA's maximum penalties are $16,550 per serious violation and $165,514 per willful or repeated violation. State Plan amounts may differ.

How to Comply: Step by Step

1. Map your exit routes. Confirm each area has at least two routes, measure widths and heights, and check door hardware and swing.
2. Check signs and lighting. Verify every exit is marked and lit, and that confusing doors are marked "Not an Exit."
3. Find your triggers. Identify which OSHA standards require an EAP or fire prevention plan for your site.
4. Write the plan. Cover all six minimum elements, plus site hazards such as chemical releases or severe weather.
5. Assign roles. Name evacuation wardens, critical-operations staff and contacts, and train them.
6. Review with employees. Walk new hires through the plan, and review it again when roles or the plan change.
7. Drill and inspect. Run evacuation drills, do routine exit inspections, and fix findings through corrective actions.

How SMS360 Helps

SMS360's Document Library gives teams one controlled place to store the current emergency action plan, fire prevention plan, evacuation maps and contact lists. Keeping one current copy makes it clear which plan is in effect, and mobile access lets wardens and supervisors open the latest plan from the floor during a drill or real event.

Review reminders help keep plans current when contacts, roles or layouts change, and storing drill records and exit inspection results alongside the plan makes it easier to show compliance during an audit.

Frequently Asked Questions

Does every employer need a written emergency action plan?

Not automatically. 1910.38 applies when another OSHA standard in Part 1910 requires an EAP, such as the portable fire extinguisher or process safety management standards. When one is required, it must be written unless the employer has 10 or fewer employees, in which case it may be communicated orally.

How many exit routes does a workplace need?

At least two exit routes are normally required, located as far apart as practical. A single exit route is allowed only when the building size, occupancy and arrangement let all employees evacuate safely. More routes may be required if two are not enough for a safe evacuation.

How wide must an exit route be?

Under 1910.36, the exit access must be at least 28 inches wide at all points, and ceilings must be at least 7 feet 6 inches high. The route must also be wide enough for the maximum permitted occupant load of each floor and must not narrow as it approaches the exit discharge.

How often does OSHA require evacuation drills?

1910.38 does not set a specific drill frequency. It requires the employer to review the plan with each covered employee when the plan is developed or the employee starts, when their responsibilities change and when the plan changes. Other standards, local fire codes or insurers may require periodic drills.