Here is a basic review of a general industry workplace’s responsibilities as it relates to EXIT signs, emergency lighting, and emergency alarms.
Can an exit sign be any size?
No, there are limitations on NOT the actual sign size, but rather the size of the letters EXIT. 1910.37(b)(7) states
Each exit sign must have the word “Exit” in plainly legible letters not less than six inches (15.2 cm) high, with the principal strokes of the letters in the word “Exit” not less than three-fourths of an inch (1.9 cm) wide.
So to put it bluntly, just because some “safety vendors” will sell us an exit sign that is 3”X3” and at a really great price does not mean they are OSHA compliant. The entire sign can be bigger, but the letters of the word EXIT must be 6” tall and each stroke made to make the letter ¾” wide.
Does my exit sign have to be one that is lit and have red letters?
YES on the lighting and NO on the red letters, but let me explain, as there are a few options for us in how we illuminate and color our exits signs. First though, how bright do you think your computer screen is right now? 1 foot candle, 10 foot candles, 100 foot candles? To give us some perspective on brightness, a movie theater is around 3-5 foot candles.
An exit sign that is lit up from an external light source must have its face surface illuminated to AT LEAST FIVE (5) foot candles. An exit sign that is lit from within has to be lit to a brightness of AT LEAST 0.06 foot lamberts. We find these requirements in 1910.37(b)(6), which states…
Each exit sign must be illuminated to a surface value of at least five foot-candles (54 lux) by a reliable light source and be distinctive in color. Self-luminous or electroluminescent signs that have a minimum luminance surface value of at least .06 footlamberts (0.21 cd/m2) are permitted.
Does OSHA require emergency lighting?
YES. Emergency lighting is required for all areas where workers may be in the event of a power outage. Although OSHA does not set a minimum foot candles, it needs to be strong enough “so that an employee with normal vision can see along the exit route” (1910.37(b)(1). And the second question we get often regarding lighting… do the emergency lights and exit signs have to be inspected/tested monthly? NO and YES; there is no OSHA requirements for monthly inspection/testing, however, OSHA does require:
Safeguards designed to protect employees during an emergency (e.g., sprinkler systems, alarm systems, fire doors, exit lighting) must be in proper working order at all times.( 1910.37(a)(4)
So we do not “have to” inspected them monthly, but we MUST ENSURE they are in the proper working order at all times. This means that some facilities may be able to do it quarterly and then some facilities may need to do it weekly! It just depends on age of the system, past problems with the system, etc.
Does OSHA require an emergency alarm system?
NOT EXACTLY, but if the facility is REQUIRED to have an Emergency Action Plan (EAP), then the facility MUST have an emergency alarm system. So what facilities are REQUIRED to have an EAP? Click Here to read my article explaining this requirement.
What maintenance and testing requirements does OSHA set for alarm systems?
An employee alarm system must be operable. Employers must install and maintain an operable employee alarm system that has a distinctive signal to warn employees of fire or other emergencies, unless employees can promptly see or smell a fire or other hazard in time to provide adequate warning to them. The employee alarm system must comply with § 1910.165
WARNING! BE VERY CAREFUL thinking that the part stating unless employees can promptly see or smell a fire or other hazard in time to provide adequate warning to them is a free ride! For example, some facilities that handle hazardous chemicals that have low odor thresholds seem to think that the mere presence of an odor is ample alarm; HOWEVER, they have a policy to “notify your supervisor if you smell XXXXX”. If a facility chooses to use odor as their alarm, then employees EVACUATE at the smell of the hazardous chemical – which I do not think facilities would want this subjective measurement as their trigger to evacuate a production line. But OSHA gives this option; but we cannot have it both ways.
1910.165 actually has some very specific testing requirements for the alarm system…
1910.165(d)(1) The employer shall assure that all employee alarm systems are maintained in operating condition except when undergoing repairs or maintenance.
1910.165(d)(2) The employer shall assure that a test of the reliability and adequacy of non-supervised employee alarm systems is made every two months. A different actuation device shall be used in each test of a multi-actuation device system so that no individual device is used for two consecutive tests.
1910.165(d)(3) The employer shall maintain or replace power supplies as often as is necessary to assure a fully operational condition. Back-up means of alarm, such as employee runners or telephones, shall be provided when systems are out of service.
1910.165(d)(4) The employer shall assure that employee alarm circuitry installed after January 1, 1981, which is capable of being supervised is supervised and that it will provide positive notification to assigned personnel whenever a deficiency exists in the system. The employer shall assure that all supervised employee alarm systems are tested at least annually for reliability and adequacy.
1910.165(d)(5) The employer shall assure that the servicing, maintenance and testing of employee alarms are done by persons trained in the designed operation and functions necessary for reliable and safe operation of the system.
How loud does my emergency alarm(s) have to be?
OSHA does not establish a minimum sound level for the basic reason as each workplace will have different ambient noise levels. But OSHA does REQUIRE that the alarm be capable of be heard in all areas where workers may be affected by the emergency.
1910.165(b)(2) The employee alarm shall be capable of being perceived above ambient noise or light levels by all employees in the affected portions of the workplace. Tactile devices may be used to alert those employees who would not otherwise be able to recognize the audible or visual alarm.
We have seen on numerous occasions that the weekly alarm tests are done by security on the weekends when the plant is empty. This is done to minimize impacts on production; however, it also tells us that the alarm system is not being tested during times when there is ambient noise so the facility does not have the ability to assess the alarms ability to meet the full intent of the standard. Sure the alarm is being tested to ensure it functions; however, the most critical functional test is that the alarm can actually be heard by workers during their work!