MODULE 17

Egress and Fire Protection

Egress and Fire Protection

What could make employees need to
escape quickly?
What are the typical escape routes?
What precautions are taken for fire
protection and prevention?

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Regulations
29 CFR 1910 Subparts E and L
29 CFR 1926 Subpart F construction
API RP 54
Section 7: Fire Protection and Prevention
6.10: Auxiliary Escape
9.3.10: At least 2 stairways on a drilling rig

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29 CFR 1910 Subpart E

Exit Routes, EAPs, and FPPs

1910.34 Coverage
Every employer is covered:
1910.34 through 1910.39 apply to
workplaces in general industry
Except mobile workplaces such as vehicles
or vessels

Exit routes
Emergency action plans
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1910.34(c) Definitions
Exit: that portion of an exit route that is
generally separated from other areas to
provide a protected way of travel to the exit
discharge.
Exit access: that portion of an exit route that
leads to an exit.
Exit discharge: the part of the exit route that
leads directly outside or to a street, walkway,
refuge area, public way, or open space with
access to the outside.
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1910.34(c) Definitions
Exit route: a continuous and unobstructed
path of exit travel from any point within a
workplace to a place of safety (including
refuge areas). Consists of three parts:
The exit access;
The exit; and,
The exit discharge.

Equivalent to Means of Egress in the Life

Safety Code and most local building and fire
codes
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1910.35 Compliance with NFPA

101-2000, Life Safety Code
Compliance with the exit route
provisions of NFPA 101-2000 will be
deemed to be in compliance with the
corresponding requirements in
1910.34, 1910.36, 1910.37

NFPA
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29 CFR 1910.36

Design and Construction

Requirements for Exit Routes

1910.36(a)(1) Basic Requirement

An exit route must be a permanent part
of the workplace
Eat
at
Mas
Place

10

No
ropes
or
rope
ladde
rs
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1910.36(a)(2) Exit separated by

fire resistant materials
Construction materials used to separate
an exit from other parts of the
workplace:
1 hour resistance 3 stories
2 hours resistance 4 stories
1 hour
2 hours
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1910.36(a)(3) Openings into an

exit must be limited
Openings into an exit: limited to those
necessary to allow access to the exit
Each opening must be protected by an
approved self-closing fire door that
remains closed or automatically closes
in an emergency

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1910.36(b) The number of exit

routes must be adequate
At least 2 routes must be available
Except for sufficiently small occupancy
see (b)(3)
As far away from each other as practical in
case one is blocked by fire or smoke
More than 2 required if all cannot evacuate
through 2 exit routes

Life Safety Code can help with this

determination
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1910.36(c)(1) Exit Discharge

Must lead directly outside or to a street,
walkway, refuge area, public way, or
open space with access to the outside
Exit
Discharge

Offices

Storage

Exit access
Fabricating shop

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Discharge

Exit
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1910.36(c)(2) Exit Discharge

The street, walkway, refuge area, public
way, or open space to which an exit
discharge leads must be large enough
to accommodate the building occupants
likely to use the exit route

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1910.36(c)(3) Exit Discharge

Exit stairs that continue
beyond the level of the exit
discharge must be
interrupted at that level by
doors, partitions, or other
effective means that clearly
indicate the direction of
travel leading to the exit
discharge
16

NOT AN

EXIT

NOT AN

EXI
T

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1910.36(d) Exit door must be

unlocked
Must be able to open exit route door
From the inside at all times
Without keys, tools, or special knowledge
Panic bar is permissible

No device or alarm that could restrict

use of route if device fails
Mental, penal, correctional facilities:
exception with constant supervision &
plan
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1910.36(e)(1) A side-hinged exit

door must be used
A side-hinged door must be used to
connect any room to an exit route
Must swing out in the direction of exit
travel if
room is designed for > 50 people or
room is a high hazard area

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1910.36(f) The capacity of an

exit route must be adequate
Must support the maximum permitted
occupant load for each floor served
See factors
for occupant
load and
capacity in
NFPA Life
Safety Code Chapter 7
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1910.36(f) The capacity of an

exit route must be adequate
Exit route
capacity
may not
decrease
toward exit
discharge

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1910.36(g) Exit minimum height

and width requirements
Ceiling at least 76
Any projection from the ceiling 68
Exit access 28 inches wide
Including all objects projecting into route
7- ft.

6 ft.- 8 in.
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1910.36(h) An outdoor exit route

is permitted.
Same minimum height and width
Additional requirements:
Guardrails on unenclosed sides
Covered if snow or ice likely to accumulate
Unless snow removed before hazard

Reasonably straight
Smooth, solid, level walkways
No dead end longer than 20 feet
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29 CFR 1910.37

Maintenance, safeguards, and

operational features for exit routes

1910.37(a) The danger to

employees must be minimized
Exit routes must be kept free of
explosive or highly flammable
furnishings or
decorations
No exit route
may lead toward
high hazard area,
unless shielded
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1910.37(a) The danger to

employees must be minimized
Exit routes free and
unobstructed: No
materials/equipment
may be placed within
exit route
Exit access must not
go through a room that
can be locked
Safeguards must be
kept in working order
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1910.37(b) Lighting and marking

must be adequate and appropriate
Exit routes adequately
lighted
Clearly visible and
marked by a sign
reading "Exit"
No decorations or signs
that obscure the
visibility of exit route
door
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1910.37(b) Lighting and marking

must be adequate and appropriate
If the direction of travel to the exit is not
immediately apparent, signs must be posted
indicating the direction of travel to the nearest
exit
Line-of-sight to an exit sign must clearly be
visible at all times
Way to exit is
not apparent
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1910.37(b) Lighting and marking

must be adequate and appropriate
Each doorway or
passage that could be
mistaken for an exit
must be marked "Not
an Exit" or similar
designation, or be
identified by a sign
indicating its actual
use (e.g., closet)
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1910.37(b) Lighting and marking

must be adequate and appropriate
Each exit sign must be
illuminated to a surface
value of at least five footcandles (54 lux) by a
reliable light source and
be distinctive in color
The word "Exit" in plainly
legible letters 6
Letters 3/4 inch thick
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1910.37(d) Exit routes during

construction, repairs, or alterations
Employees must
not occupy a
workplace until
the exit routes are
ready in occupied
portion

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1910.37(d) Exit routes during

construction, repairs, or alterations
Employees must not be exposed to
hazards from construction activities that
are beyond the normal permissible
conditions, or that would impede exiting
the workplace

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1910.37(e) Alarm system

Alarm system must be installed and
maintained in operable condition
To warn of fire or other emergencies
Unless employees can promptly see or
smell fire or hazard in time
Must comply with 1910.165 (in Subpart L)

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29 CFR 1910.38

Emergency Action Plans

1910.38 Emergency action plans

(EAP)
Emergency action plan:

EAP

In writing
Kept in the workplace
Available to employees for
review

Employer with 10 or
fewer employees may
communicate the plan
orally to employees
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1910.38(c) Minimum elements of

an emergency action plan
1. Procedures for reporting a fire
or other emergency
2. Procedures for emergency
evacuation, including type of
evacuation and exit route
assignments
3. Procedures for employees who
remain to operate critical plant
operations before evacuating
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1910.38(c) Minimum elements of

an emergency action plan
4. Procedures to account for all
employees after evacuation
5. Procedures to be followed by
employees performing rescue or
medical duties
6. Name or job title of every employee
who may be contacted by employees
who need more information about the
plan
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Alarms, training, review

d. Alarm system must use distinctive signals
for each purpose, comply with 1910.165
e. Designate and train employees to assist
in safe, orderly evacuation of others
f. Review of EAP with each employee:

37

When plan developed or employee assigned

When employees responsibilities under the
plan change
When the plan changes
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29 CFR 1910.39

Fire Prevention Plans

1910.39(b) Written and oral fire

prevention plans
Any required fire prevention plan must:
Must be in writing,
Be kept in the workplace, and
Be made available to employees for review

Employer with 10 or fewer employees

may communicate the plan orally to
employees
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1910.39(c)(1) Minimum elements

of a fire prevention plan
List of all major fire hazards
Proper handling and storage
procedures for hazardous materials
Potential ignition sources and their
control
Type of fire protection equipment
necessary to control each major hazard
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1910.39(c)(1) Minimum elements

of a fire prevention plan, contd
Procedures to control accumulations of
flammable and combustible waste
Maintenance procedures for safeguards on
heat-producing equipment to prevent ignition
of combustible materials
Name or title of employees responsible for
maintaining equipment to prevent or control
sources of ignition or fires
Name or title of employees responsible for
control of fuel source hazards
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1910.39(e) Employee
information
An employer must inform employees
upon initial assignment to a job of the
fire hazards to which they are exposed.
An employer must also review with
each employee those parts of the fire
prevention plan necessary for selfprotection.
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29 CFR Subpart L

Fire Protection

Organization of 1910 Subpart L

44

155 Scope, application, definitions

156 Fire brigades
157 Portable fire extinguishers
158 Standpipe and hose systems
159 Automatic sprinkler systems
160-163 Fixed extinguishing systems
164 Fire detection systems
165 Employee alarm systems
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29 CFR 1910.155

Scope, Application, and

Definitions

Scope and Application

Fire brigades, fire suppression
equipment, fire detection systems,
alarm systems
Applies to all employments except
maritime, construction, and agriculture

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Definitions
Class A fire: Ordinary combustible materials

Paper
Wood
Cloth
Some rubber and plastic.

Class B fire:

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Flammable or combustible liquids

Flammable gases
Greases
Some rubber and plastic
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Definitions
Class C fire: Energized electrical equipment
Employee safety requires nonconductive
extinguishing media

Class D fire: Combustible metals

48

Magnesium
Titanium
Zirconium
Sodium
Lithium
Potassium
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Definitions
Dry chemical: small particles of
chemicals supplemented for dryness
and flow
Bicarbonates
Potassium chloride
Monoammonium phosphate

Dry powder: compound used to

extinguish or control Class D fires
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Definitions
Enclosed structure:
Has a roof or ceiling and at least 2 walls
May accumulate smoke, toxic gases and
heat

Foam: Bubbles form a blanket over

liquid, sealing combustible vapors
Gaseous agent: Diffuses uniformly to
extinguish fires
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29 CFR 1910.156

Fire Brigades

Scope and Application

Organization, training, PPE
Fire brigades established by employer
Industrial fire departments
Private or contractual fire departments

PPE requirements only apply to interior

structural firefighting

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Organization and Training

Organizational statement available
Physical capability
No heart disease, epilepsy, or emphysema
without physicians certificate of fitness

Training and education

Beforehand and frequently enough
Examples of quality training programs
Special hazards and written procedures
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Firefighting Equipment
Maintain and inspect at least annually
Portable fire extinguishers and
respirators: inspect at least monthly
Remove and replace unserviceable or
damaged equipment

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Protective clothing
For interior structural firefighting
Not required for incipient stage firefighting

Provide at no cost and assure use

Protect head, body, and extremities

55

Foot and leg protection

Body protection
Hand protection
Head, eye, and face protection
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Respiratory protection devices

Provided to and used by fire brigade
members
Meet 1910.134 as well
SCBA requirements

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29 CFR 1910.157

Portable Fire Extinguishers

Scope and application

Placement, use, maintenance, testing
For portable fire extinguishers to be
used by employees inside structures
(e) and (f) only if not for employee use
Partial exemptions:
Policy requiring total evacuation; FPP and
EAP; extinguishers not present
Only designated employees authorized
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General requirements
Provide, mount, locate and identify
Readily accessible to employees without
possible injury

Only approved fire extinguishers

No carbon tetrachloride or
chlorobromomethane extinguishers
Maintain fully charged and operable in
designated places
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Selection and distribution

Based on fire classes, size of hazard
Class A: 75 ft. travel distance to
extinguisher, or standpipe
Class B: 50 ft. travel distance to
extinguisher
Class C: Based on pattern for Class A/B
Class D: 75 ft. travel distance to
extinguishing agent
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Fire Extinguisher Classes

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Inspection, maintenance, and

testing
Portable extinguishers or hose visually
inspected monthly
Annual maintenance check record available
Maintenance 6 years after recharge or
hydrostatic test for dry chemical extinguishers
with 12-year hydrostatic test requirements
Alternate equivalent protection during
maintenance/recharging
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Hydrostatic testing
Performed by trained persons with
suitable testing equipment and facilities
Test interval given for various types of
extinguishers
Tested when new evidence of corrosion
or mechanical injury
Details for various types
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Training and education

If employees are to use fire
extinguishers, the employer must
educate them on principles and hazards
EAP-designated employees trained on
appropriate equipment
Upon employment and at least annually

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Standpipe and hose systems

For smaller systems not Class I
Protected against mechanical damage
Repaired promptly if damaged

Equipment: designed for prompt use

Water supply: minimum 100 gal/min
Tests and maintenance

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1910.159-163: Sprinklers and

Fixed Extinguishing Systems
Sprinklers only if required by OSHA
Fixed extinguishing systems
Discharge alarms and safeguards
Inspection and maintenance
PPE for rescue of employees trapped

Dry chemical
Gaseous agent
Water spray and foam
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Fire detection systems

Restore to normal condition ASAP after each
test or alarm spares available
Maintenance and testing
Protect from corrosion, physical impact
Do not support by wires or tubing
Designed to operate in time, provide a
warning
Delay only if necessary for immediate safety
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Employee alarm systems

All local fire alarm signaling systems
used to alert employees
Enough warning for emergency action
of safe escape
Perceived above ambient noise/light
Tactile devices when necessary

Distinctive and recognizable

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Employee alarm systems

Explain to each employee how to report
emergencies
Establish procedures for emergency
alarm
Restore to normal condition ASAP after
each test or alarm spares available

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Employee alarm systems

Maintain in operating condition except
during repairs or maintenance
Test for reliability/adequacy every 2
months if unsupervised
Back-up means of alarm when out of
service
Supervised systems notify personnel of
deficiencies test once/year
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Employee alarm systems

Manually operated actuation devices
(fire alarm pulls)
Unobstructed
Conspicuous
Readily accessible

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API RP 54

Fire Protection on Oil and Gas

Well Sites

API RP 54 Requirements
Drilling rigs: at least 4 20-pound
capacity, Class BC rated fire
extinguishers
Well servicing rigs: at least 2 20-pound
capacity, Class BC rated fire
extinguishers
Available near all welding
Firefighting equipment also includes
water hoses and drilling fluid guns
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