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|Standard Number:||1910.37(b)(7); 1910.35; 1910.34; 1910.36; 1910.37; 1910.6|
May 25, 2022
Scott Brody, EIT
11 Largo Lane
Livingston, New Jersey 070039
Dear Mr. Brody:
Thank you for your letter to the Occupational Safety and Health Administration (OSHA), requesting clarification of OSHA standard 29 CFR 1910.37(b)(7), as it may apply when using the International Standards Organization (ISO) emergency exit symbol.1 This letter constitutes OSHA's interpretation only of the requirements herein, and may not be applicable to any questions not delineated in your original correspondence. Your paraphrased questions, and our responses are as follows:
Question 1: Does §1910.37(b)(7) permit the display of the ISO's international emergency exit symbol as defined in ISO 7010 beside the mandatory EXIT text on an existing exit sign?
Response: Yes. As an initial matter, §1910.37(b)(2) requires that "[e]ach exit must be clearly visible and marked by a sign reading 'Exit.'" In addition, §1910.37(b)(7) specifies the required dimensions for the text of the word "exit" on such signs. Neither §1910.37 nor any other OSHA standard prohibits the display of another emergency exit symbol, such as ISO's emergency symbol, alongside an existing exit sign that meets §1910.37(b)(7)2 requirements. Moreover, OSHA standard §1910.35 states, "OSHA will deem an employer demonstrating compliance with the exit-route provisions of NFPA 101, Life Safety Code, 2009 edition, or the exit-route provisions of the International Fire Code, 2009 edition, to be in compliance with the corresponding requirements in §§1910.34, 1910.36, and 1910.37 (incorporated by reference, see section §1910.6)."
Where approved by the authority having jurisdiction, NFPA 101-2009 allows the use of pictograms in compliance with NFPA-170, Standard for Fire Safety and Emergency Symbols, in lieu of, or in addition to, signs with text. When pictograms are used, the graphics must provide equal visibility and illumination as signs with text and meet all other requirements of NFPA 101-2009, chapter 7.10 (e.g., size of sign, testing and maintenance, mounting location, and power source). Employers should verify state, local, or other jurisdiction building and/or fire code requirements as codes may vary and contain other limitations.
Question 2: May an employer use the larger ISO 7010 arrow in lieu of the chevron directional indicator specified in NFPA 101-2009 along with a NFPA-compliant "EXIT" sign?
Response: Yes. As stated above, §1910.35 recognizes an employer's compliance with the exit-route provisions of NFPA 101, Life Safety Code, 2009 edition, or the exit-route provisions of the International Fire Code, 2009 edition, to be in compliance with OSHA's standards. NFPA 101-2009, Chapter 220.127.116.11 states that "pictograms in compliance with NFPA 170, Standards for Fire Safety and Emergency Symbols, shall be permitted." NFPA 170, Chapter 18.104.22.168 provides that "symbols shall be permitted to be used in combination with other symbols, either vertically or horizontally, on the same sign or on separate signs adjacent to each other." NFPA 170, Chapter 4.2 and Table 4.2 illustrate the symbols permitted for general use and displays various options with required specifications. Table 4.2 contains and permits the use of the same directional arrow as permitted by ISO 7010. Hence, the ISO 7010 directional arrow may be used in a NFPA-compliant "exit" sign where permitted by state or local jurisdiction.
Question 3:Notwithstanding state and local requirements, would the exit signs pictured in my letter meet the requirements of §1910.37(b)(7)?
Response:Upon review of your supplied photo examples and as previously stated, OSHA will deem an employer demonstrating compliance with the exit-route provisions of NFPA 101-2009 edition, to be in compliance with the corresponding requirements in §1910.37. Additionally, pictograms must provide equal visibility and illumination as signs with text and meet all other requirements of NFPA 101-2009, section 7.10 (e.g., size of sign, testing and maintenance, mounting location, and power source). Since OSHA does not have a standard prohibiting the display of another emergency exit symbol, such as ISO's emergency symbols, alongside an existing exit sign that meets §1910.37(b)(7) requirements, there would be no prohibition of displaying both signs together in such scenarios.
Based on NFPA 101-2009, Ch. 22.214.171.124 and NFPA 170, Ch. 4.2 and Table 4.2, your proposed type 1 sign containing the text "EXIT" with the ISO 7010 moving person symbol (displayed side-by-side in the image below), complies with the requirements set forth in the relevant sections, and therefore meets applicable OSHA's standards.
NFPA 170, Chapter 126.96.36.199 states that "symbols shall be permitted to be used in combination with other symbols, either vertically or horizontally, on the same sign or on separate signs adjacent to each other." Hence, the placement of the ISO 7010 moving person next to the text "EXIT" on the same sign is permissible. NFPA 170, Table 4.2 specifies that this symbol is required to be on a green background, with a white opening, and the person image in green. Thus, this sign is compliant with NFPA 101-2009 and NFPA 170, and acceptable under OSHA's standards.
However, due to the combined use of these symbols on the same sign and the color of the sign and symbols, the second group of proposed signs containing arrows combined with the ISO 7010 moving person symbol, do not meet the requirements in NFPA 170.
NFPA 170, Table 4.2 contains very specific requirements when displaying the directional arrow with the ISO 7010 moving person on the same sign. According to Table 4.2, for painted signs, when multiple symbols are combined, as depicted in your proposed signs, the background must be white and the arrows must be red or black. If you are using a backlit sign, then the doorway, arrows and any lettering may be in green or red with a white background. Your proposed signs have a green background with white lettering and arrow. While the separate white "EXIT" signs with the red lettering are compliant with NFPA 101-2009 and OSHA's regulations, all three separate green signs depicted in the images above, do not meet NFPA 170 requirements and therefore are not OSHA-compliant.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, such letters may be affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have any questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.
Kimberly Stille, Director
Directorate of Enforcement Programs
1 Human figure moving (to the right or to the left) through doorway to indicate an escape route to a place of safety. The square field has a green background with a white door opening and the human figure is green per NFPA 170-2021. The figure can be found at: https://www.iso.org/obp/ui#iso:grs:7010:E002.
2 In accordance with §l 910.37(b)(7), "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."
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