General Industry (29 CFR 1910)

Design and Construction Requirements for Exit Routes

Verified vs OSHA sources · 2026-10-05

29 CFR 1910.36

29 CFR 1910.36 sets how exit routes must be designed and built: they must be permanent parts of the building, normally at least two separate exits located far enough apart to stay usable if one is blocked, of adequate width and height, fire-resistance-rated, and discharging to a safe area outside.

29 CFR 1910.36 at a glance

What it requires: Enough properly designed, separated exit routes to evacuate everyone safely
Number: At least two exit routes must be available (more if the number of employees/size requires)
Minimum size: Exit route at least 28 inches wide and 7 ft 6 in high (headroom)
Fire resistance: Exit-route separations rated 1 hour (≤3 stories) or 2 hours (4+ stories)
Max penalty (2026): $16,550 per serious violation; $165,514 per willful
The #1 confusion: Design (1910.36) is how routes are built; maintenance (1910.37) is keeping them usable

What 29 CFR 1910.36 requires (plain English)

29 CFR 1910.36 sets the design and construction requirements for exit routes: the permanent, continuous, and unobstructed paths of travel from any point in a workplace to a place of safety. It answers how many exit routes a workplace must have, how they must be arranged and separated, and how big they must be, so that employees can evacuate promptly during a fire or other emergency. It works with 1910.37 (maintenance and operational features) and the emergency action plan requirements of 1910.38.

The core design rule is redundancy: at least two exit routes must be available in a workplace to permit prompt evacuation, located as far apart as practical so that if one is blocked by fire or smoke the other remains usable. More than two are required when the number of employees, the size of the building, or the arrangement of the workplace means two would not allow everyone to evacuate safely. (A single exit route is allowed only where the number of employees, the size of the building, its occupancy, and the arrangement allow all employees to evacuate safely during an emergency.) Exit routes must be separated from other workplace areas by fire-resistant construction: generally a one-hour fire-resistance rating for buildings of three or fewer stories and two hours for four or more.

The standard also fixes the physical dimensions and features that make a route usable: an exit route must be at least 28 inches wide at all points (wider where the occupant load requires), with headroom of at least 7 feet 6 inches, and free of anything that could reduce its clear width. An exit door must be side-hinged, swing out in the direction of travel where serving high-hazard areas or 50+ occupants, and connect directly to the outside or to a safe area. These design requirements set the stage that 1910.37 then requires be kept unobstructed, lighted, and marked.

The regulatory text

“At least two exit routes must be available in a workplace to permit prompt evacuation of employees and other building occupants during an emergency, except as allowed in paragraph (b)(3) of this section. The exit routes must be located as far away as practical from each other so that if one exit route is blocked by fire or smoke, employees can evacuate using the second exit route.”

29 CFR 1910.36(b)(1)

Key facts about 29 CFR 1910.36

At least two exit routes must be available, located as far apart as practical (1910.36(b)(1)).
More than two exit routes are required when the number of employees or the building size/arrangement demands it.
A single exit route is permitted only where all occupants can evacuate safely given the size, occupancy, and arrangement.
Exit routes must be separated by fire-resistant construction: 1-hour rating (≤3 stories) or 2-hour (4+ stories).
An exit route must be at least 28 inches wide at all points and have at least 7 ft 6 in of headroom.
Exit routes must be permanent and generally lead directly outside or to a street, walkway, or open space with access to the outside.
1910.36 covers DESIGN; 1910.37 covers ongoing MAINTENANCE and operational features.

Scope: who 29 CFR 1910.36 applies to

Regulatory framework: General Industry (29 CFR 1910)
Citation reference: 29 CFR 1910.36
Enforcement status: In force and enforced
Jurisdiction: Federal OSHA (29 State-Plan jurisdictions may be stricter)

State-Plan states (e.g. California, Washington, Michigan) operate OSHA-approved programs that must be at least as effective as federal OSHA and frequently impose higher penalties or additional requirements. Confirm the rule as adopted in your state.

Key requirements of 29 CFR 1910.36

#	Employer obligation
1	Exit routes must be permanent
2	Exit access must be at least 28 inches wide
3	Exits must be fire-resistant rated
4	Exits must discharge outside the building

Summarized from the text of 29 CFR 1910.36. Always read the full regulation for the binding language.

Common Exit Route Design violations

Deficiencies OSHA cites under 29 CFR 1910.36 include the ones below, in no particular order. Distinct deficiencies can be cited as separate items, and each serious item carries up to $16,550 (2026). Broader per-instance stacking exists but is a discretionary, case-by-case OSHA enforcement policy, not an automatic multiplier.

Fewer exit routes than required for the number of employees / building size (1910.36(b)).
Exit routes not separated by adequate fire-resistant construction (1910.36(a)(1)).
Exit route narrower than 28 inches, or with headroom under 7 ft 6 in (1910.36(g)).
Exit route that does not lead to a place of safety (street, walkway, or open space): 1910.36(a).
Only one exit route where the size/occupancy requires two or more.

Design (1910.36) vs. maintenance (1910.37)

OSHA's exit-route requirements split into two standards that are easy to confuse. 1910.36 governs the DESIGN and construction of the routes (how many there are, how far apart, how they are separated by fire-resistant construction, their minimum dimensions (28 inches wide, 7 ft 6 in headroom), and) at 1910.36(d): that an exit door must be unlocked from the inside. 1910.37 governs the ongoing MAINTENANCE and operational features: keeping routes unobstructed, adequately lighted, and marked with 'Exit' signs. A building can be designed with perfect exit routes and still be cited under 1910.37 if a route is later blocked by stored materials; a chained exit door, by contrast, is cited under 1910.36(d)(1). Together with the emergency action plan (1910.38) and fire prevention plan (1910.39), they form OSHA's means-of-egress framework.

What OSHA inspectors look for

A compliance officer checks that the building has enough exits for its occupancy, adequately separated, that exit doors swing out and meet the required width, and that enclosures carry the proper fire-resistance rating. Too few exits, and exits that discharge into a locked or unsafe area, are design findings.

Example: how a violation is cited

A workspace is served by a single exit, so a fire near that door leaves workers trapped. OSHA cites 1910.36(b) for failing to provide at least two exit routes where the number of employees and the layout require them: a design flaw with fatal potential, penalties from $16,550.

Illustrative example, not a specific OSHA case.

Exit Route Design compliance checklist

Use this to evaluate your compliance with 29 CFR 1910.36. Each item is a key requirement OSHA may verify during an inspection.

Provide at least two exit routes (more if occupancy/size requires), located as far apart as practical.
Separate exit routes from the workplace with the required fire-resistant construction (1 or 2 hour).
Ensure each exit route is at least 28 inches wide and provides at least 7 ft 6 in of headroom.
Confirm each exit route leads to a place of safety (outside, or a street/walkway/open space with outside access).
Use side-hinged exit doors that swing in the direction of travel where required by hazard/occupant load.
Coordinate the design with 1910.37 maintenance and the 1910.38 emergency action plan.

2026 penalties for 29 CFR 1910.36

Maximums set by 29 CFR 1903.15(d). 2026 amounts unchanged from 2025 (no CPI adjustment; OMB M-26-11). Not an increase. The 2025 OSHA penalty levels remain in effect for 2026; OSHA made no inflation adjustment for 2026. 29 CFR 1903.15 identifies January 15, 2025 as the effective reference for these amounts, while OSHA's public penalties page currently references penalties assessed after Jan. 15, 2026.

Violation type	Minimum	Maximum	When it applies
Serious	$1,085	$16,550	Substantial probability of death or serious physical harm.
Other-Than-Serious	$0	$16,550	Relates to safety/health but unlikely to cause death or serious harm.
Willful	$11,823	$165,514	Intentional, knowing, or voluntary disregard of the requirement.
Repeated	$4,256	$165,514	A substantially similar violation cited within the last 5 years.
Failure to Abate	None	$16,550/day	up to $16,550 per day; total capped at 30x the daily amount (FOM Ch.6)

Exit-route design issues surface in fire-safety and programmed inspections. Serious violations reach $16,550 and willful or repeat violations $165,514; design deficiencies are often cited with 1910.37 maintenance items.

Maximums and the willful minimum are set by 29 CFR 1903.15(d); the serious and repeated minimums are OSHA policy floors from its annual penalty adjustment memo. OSHA applies gravity-based and size, good-faith and history reductions (FOM CPL 02-00-164 Ch.6). Estimates only, not legal advice.

The business case for Exit Route Design compliance

Exit-route design decides whether people can get out when one path is blocked by fire or smoke. Two remote exits, adequate width, and fire-rated enclosures are the structural features that make an evacuation survivable, and they must be built in, not added later.

Free compliance tools for 29 CFR 1910.36

Emergency Action Plan Builder

Exit Route Design penalties by state

Penalties and enforcement vary by state. State-Plan states may impose higher penalties and additional requirements beyond federal 29 CFR 1910.36.

Alabama Arkansas Colorado Connecticut Delaware District of Columbia

View all 50 states + DC →

Frequently asked questions about 29 CFR 1910.36

How many exit routes does a workplace need?

At least two, under 1910.36(b)(1): located as far apart as practical so that if one is blocked by fire or smoke, employees can use the other. More than two are required when the number of employees, the size of the building, or its arrangement means two would not allow everyone to evacuate safely. A single exit route is permitted only in the narrow case where the size, occupancy, and arrangement let all occupants evacuate safely during an emergency.

What are the minimum size requirements for an exit route?

Under 1910.36(g), an exit route must be at least 28 inches wide at all points (and wider where the occupant load requires), and must provide headroom of at least 7 feet 6 inches. Objects that project into the exit route must not reduce its required width, and the route must be a permanent part of the workplace.

How must exit routes be separated from the rest of the building?

Exit routes must be separated by fire-resistant construction. Generally, materials providing a one-hour fire-resistance rating are required when the exit route connects three or fewer stories, and a two-hour rating when it connects four or more stories. This separation keeps the exit route usable even as fire and smoke develop in the areas it passes.

Where must an exit route lead?

An exit route must lead to a place of safety. Under 1910.36, an exit route is a continuous and unobstructed path of exit travel from any point within a workplace to a place of safety: normally the outside of the building at ground level, or a street, walkway, refuge area, public way, or open space with access to the outside. The exit discharge must lead directly outside or to a safe area, so occupants can move fully away from the building during an emergency.

Regulatory history of 29 CFR 1910.36

The exit route standards (1910.34–1910.39, Subpart E) were reorganized and rewritten in plain language in 2002, drawing heavily on NFPA 101 (the Life Safety Code). 1910.36 covers the design and construction of exit routes; 1910.37 covers their ongoing maintenance and operational features; and 1910.38/1910.39 cover emergency action and fire prevention plans.

Related glossary terms

Key terms that appear in 29 CFR 1910.36, each with a full plain-English explainer.

Emergency Action Plan Fire Prevention Plan

Related guides & articles

OSHA Top 10 Most-Cited Violations 2026

Related OSHA standards

29 CFR 1910.37

Exit Route Maintenance

29 CFR 1910.38

Emergency Action Plans

29 CFR 1926.501

Fall Protection

#1 most cited

29 CFR 1910.1200

HazCom / GHS

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Primary sources

OSHA figures on this page are imported from HazComFast's verified regulatory module (verified 2026-10-05 against eCFR, OSHA.gov, and the Federal Register).

This page is an educational summary, not legal advice. OSHA standards and penalty amounts change; confirm requirements against the current regulation and your applicable State-Plan before acting.

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