Exit strategy: The importance of keeping exit doors unlocked

Date Posted: 06/16/2025
Warehouse exit door with safety railings and exit sign, highlighting OSHA compliance.

Employees must be able to open an exit route door from the inside at all times without keys, tools, or special knowledge. This requirement is found in 29 CFR 1910.36, OSHA’s Exit routes standard, and has been part of the regulation for decades. Yet, in December 2021, OSHA inspectors in Wisconsin responded to a referral from local fire officials and found a retailer had closed and padlocked exit doors on the inside with a bike lock and a board. Store managers told inspectors this was a frequent practice — when employees were present! — because the doors needed repairs to close properly.

During a similar inspection in Ohio, OSHA inspectors discovered barrel locks on the inside of a double-door emergency exit. This requires special knowledge and additional time to open, potentially preventing employees from exiting quickly and safely in an emergency.

Fast forward to fiscal year 2024, and the requirement to ensure exit route doors can be opened without keys, tools, or special knowledge was the top violation of 1910.36!

What are OSHA’s requirements?

In addition to ensuring exit route doors can be opened without keys, tools, or special knowledge, further requirements are found in 1910.36(d):

  • A device such as a panic bar that locks only from the outside is permitted on exit discharge doors. In a letter of interpretation, OSHA says the use of an electronic device that must be pressed before the panic bar can be activated, such as a “Push to Exit” button, violates the intent of 1910.36(d)(1). Employers using this type of system will be cited. Employees trying to evacuate a smoke-filled room may not be able to locate the electronic device and would be trapped at the exit door. Depression of the panic bar must open the exit without any prior action. 
  • Exit route doors cannot have any device or alarm that would restrict emergency use of the exit route if the device or alarm fails.

An exit route door may be locked from the inside only in mental, penal, or correctional facilities and then only if supervisory personnel are continuously on duty and the employer has a plan to remove occupants from the facility during an emergency.

Related Video

OSHA requires employers to provide clearly marked permanent exit routes and adequate exits for employees to leave safely in an emergency. Let's take a high-level look at the requirements. 

Each exit must be marked by a sign that reads EXIT. The line-of-sight to the exit sign must be clearly visible at all times and the exit signs must be properly illuminated. Each exit door must be free of decorations or other signs that obscure it's visibility. Any doorway or passage that might be mistaken for an exit must be marked "Not an exit" or with an indication of its actual use, such as store room. 

Exit routes must be kept clear and they must have adequate lighting. The route can't lead employees toward a dead end or through a room that can be locked. Exit routes must be free of highly flammable furnishings or decorations. The exit route must not require the worker to pass through areas or unshielded materials that burn very quickly, emit poisonous fumes, or are explosive. 

Signs must be posted along the exit route to indicate the direction of travel to the nearest exit. 

Exit doors must be able to be readily opened without have to use keys, tools, or special knobs. They cannot have any alarm or device the restricts emergency use if the device fails. 

Exit discharges must lead directly to outside, to a street, walkway, or to an open space with access to the outside. The area beyond the exit has to have enough room to accommodate the people who are likely to use the exit. 

And finally, employees should be familiar with at least two exits from their workplace and keep all exits and exit routes free from obstructions.

How Safety Management Suite Can Help

Being prepared for workplace emergencies means expecting the unexpected. It's not just about having written plans; it's also about ensuring the proper design and construction of exit routes, providing safe access for your employees, and making sure they know where to go in case of an emergency. If you’ve got regulatory or other compliance questions, our experts can help! Submit your question through the Expert Help feature in the J. J. Keller® SAFETY MANAGEMENT SUITE. Our experts typically respond in a few hours, and no more than one business day.

E-mail Newsletter

Sign up to receive the weekly EHS Insider email newsletter for safety articles, news headlines, regulatory alerts, industry events, webcasts, and more.