DOE/EH-0218 --- Issue No. 91-03 --- 10/91

Locked/Obstructed Emergency Exits
Compromise Worker Safety

Ensuring the safety of workers while maintaining facility security is an issue that frequently confronts Department of Energy (DOE) facility management. Part 1910.36 of Title 29 of the Code of Federal Regulations (CFR) explicitly states that "No lock or fastening to prevent free escape from the inside of any building shall be installed." To ensure safe egress from a work area in an emergency situation, these Occupational Safety and Health Administration (OSHA) emergency egress requirements must be met. However, DOE Tiger Teams have reported "means of egress" findings, including locked and obstructed doors, at a majority of the facilities evaluated.

Worker Safety vs. Facility Security

The potential for a conflict between ensuring worker safety and ensuring facility security was tragically illustrated by the recent fire at the Imperial Food Products Plant in Hamlet, North Carolina that resulted in the death of 25 employees and injuries to another 54 workers. Preliminary investigations into this fire indicate that, in violation of OSHA requirements, plant doors had been locked to prevent theft.

DOE Order 5480.4, "Environmental Protection, Safety, and Health Protection Standards," requires mandatory compliance with national fire codes, including National Fire Protection Association (NFPA) Standard 101, "Life Safety Code." In addition, DOE Order 5480.7, "Fire Protection," requires that "Department of Energy buildings meet those requirements of 29 CFR Part 1910 that are applicable to exits and fire protection features." Compliance with these standards and regulations is an essential element of worker safety.

DOE facilities are designed with multiple exits, featuring doors that are readily accessible, easily opened, and discharge into an open space that facilitates rapid movement away from the building, as required by OSHA in 29 CFR Part 1910. However, doors that meet these criteria also provide facility access, which may contribute to a compromise of security. In cases where access to sensitive information or equipment must be controlled, DOE facility security staff frequently authorize the installation of locks to restrict entrance into the sensitive area. Locks for doors that lead to areas where workers could inadvertently be exposed to toxic substances are also authorized by facility security when required. To comply with OSHA regulations, these security-authorized locks must open easily from the inside.

Locked Doors

During a recent Tiger Team site visit to one DOE facility, locks were found on exit doors of a laboratory. The locks had been installed as a safety precaution to keep workers from entering the laboratory. The NFPA Life Safety Code, Paragraph 5-2.1.5.1 states that "Doors shall be arranged to be readily opened from the egress side whenever the building is occupied." It also states that "locks, if provided, shall not require the use of a key, tool, special knowledge or effort for operation from the inside of the building." All locks on exit doors must meet this requirement. Tiger Teams also found locked exits at several other facilities. In some cases, the locks had been installed to protect workers from exposure to a potentially dangerous situation; in other cases, the locks were installed for the sake of facility security.

Blocked/Obstructed Doors

Both OSHA regulations and the NFPA Life Safety Code require unobstructed egress from buildings. The Life Safety Code states that "means of egress shall be free of obstructions that would prevent its use"; while the OSHA requirements of 29 CFR 1910.36 (b)(4) require exits to be "...maintained so as to provide free and unobstructed egress from all parts of the building or structure at all times when it is occupied." DOE Tiger Teams "means of egress" findings include many instances of facility exit doors being blocked by heavy equipment or otherwise obstructed to the extent that building egress was impeded. Obstructions ranged from office furniture, such as the typewriter stand blocking the emergency exit at one facility, to heavy equipment, such as the electronics and instrument cabinet at another facility. Such obstructions, which are usually inadvertent, are violations of both the NFPA Life Safety Code and OSHA regulations.

Recommendations

It is imperative that all DOE facilities meet DOE/OSHA/NFPA requirements related to emergency egress. The following recommendations should be implemented to ensure worker safety in emergency conditions.

• Perform regular fire safety assessments/fire department inspections to ensure that emergency exits area adequate and are not locked, blocked, or otherwise obstructed. (Guidance on the scope and frequency of such assessments and inspections can be found in the DOE Fire Protection Resource Manual.)

• Establish and maintain a means for consultation between fire safety specialists and security specialists to ensure that the needs of both disciplines are reflected in the safe design and operation of facilities

• Maintain a system to assure that DOE fire protection criteria related to emergency exits are incorporated in the plans and specifications of all new facilities and for modifications to existing facilities. This includes maintaining emergency exits during all construction activities.

• Take adequate compensatory measures when an emergency exit is temporarily obstructed or locked for construction or other activities. Such measures include providing additional exit signs and employee instruction.

For additional information on this topic, call Dennis Kubicki, FTS 233-4794; Commercial (301) 903-4794.

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