OSHA standards 1910.37 and 1910.38 set federal requirements for exit routes and emergency action plans in workplaces—including rules on how exit signs and emergency lighting must perform. This guide helps you stay compliant and inspection-ready under U.S. workplace safety law.
Related compliance planning: For adopted-code and state contact research, use the U.S. fire codes hub, state fire marshal directory, and Title 24 guide.
🏢 What Are OSHA 1910.37 & 1910.38?
1910.37 covers the physical requirements for exit routes—doors, signage, and lighting. 1910.38 addresses emergency action plans (EAPs), including evacuation procedures and training. Together, these rules ensure that people can exit a workplace safely during emergencies.
🚪 Exit Sign Requirements Under OSHA
- Exit signs must be clearly visible and continuously illuminated
- Each exit must be marked by a sign that reads "EXIT" in letters at least 6 inches high
- Directional arrows are required when the path to the nearest exit isn’t obvious
- Signs must remain lit during power outages using backup battery or emergency power
OSHA references UL 924 for performance but enforces visibility and functionality under 1910.37(b).
💡 Emergency Lighting Requirements
- Exit routes must be adequately lit—minimum 1 footcandle along the path of egress
- Lighting must activate immediately during power failure
- Fixtures must be maintained and tested to ensure operability
Workplace lighting systems are also subject to OSHA’s general duty clause, meaning any failure to provide adequate emergency lighting may result in citations.
📋 Emergency Action Plan (1910.38)
- Employers must maintain an EAP that includes evacuation procedures
- Clearly marked exit routes must align with the EAP
- Designated employees must be trained in emergency lighting and signage use
- All occupants must understand the location and use of exits during an emergency
Training, signage, and route lighting must all work together to comply with OSHA.
❓ OSHA Compliance FAQ
-
Does OSHA require UL 924?
OSHA doesn’t enforce UL 924 directly, but it relies on UL 924 to define acceptable emergency lighting performance. -
Are monthly tests required?
Yes. OSHA expects emergency lighting systems to be maintained and ready at all times. -
Are self-luminous signs allowed?
Yes, if they meet OSHA’s visibility and duration standards.
📚 Helpful Resources
🧠 Final Thoughts
OSHA compliance for emergency lighting starts with visibility, reliability, and clear planning. Exit signs and backup lights are essential parts of workplace safety—and must be installed, maintained, and supported by an active emergency action plan.