An industry contact recently asked me what five issues I expected OSHA would be focusing its enforcement efforts on for the balance of this year. Here was my response:
1. Emergency Exits & Exit Routes – A couple of months
Last month, OSHA issued an enforcement memorandum directing inspectors to scrutinize whether employers provide and maintain adequate means of exit; i.e., unlocked, unobstructed, and clearly marked exit doors and exit routes and doors that comply with 29 C.F.R. 1910 Subpart E – Means of Egress (specifically, the various requirements of 1910.36). The memo was issued in response to a deadly explosion and ammonia release at a poultry processing plant in China on June 4, 2013, in which at least 120 employees lost their lives, many because they were unable to exit the plant due to blocked or locked exits.
In the enforcement memorandum, OSHA announced that:
“During inspections of all workplaces [Compliance Safety & Health Officers] should be mindful of whether the employer has provided and maintained adequate means of egress from work areas; e.g., adequate number of exit routes are provided, exit routes are free and obstructed, and exit doors are not locked.”
This list of items for review is consistent with the criteria OSHA identified in its Emergency Exit Routes Fact Sheet. Here are the basic requirements for complying with 1910.36 set forth in OSHA’s regulations and the Fact Sheet:
Although the Enforcement Memorandum features the tragic anecdote about the Chinese poultry plant, OSHA’s Director of the Directorate of Enforcement specifically instructs his enforcement team to look out for egress issues in inspections at “all workplaces.” …