“Your crew members wouldn’t be able to quickly exit the building during an emergency,” said Tammy, the compliance officer.
“What makes you say that?” asked George, the supervisor.
“One of the exit doors is locked with a deadbolt, which means workers would need special knowledge or tools to open it,” said Tammy.
“There’s no special knowledge or tools required to open that door,” replied George.
“I disagree,” said Tammy. “In fact, I tried to open it myself, but I couldn’t figure it out. Finally, one of your crew members showed me how to do it.”
“So you were eventually able to open the door, which proves that it’s not hard to do,” said George.
“You’re missing the point,” said Tammy. “Workers can’t be fiddling with a door during an emergency. It has to be easy to open the door without any special knowledge or tools in order to maintain compliance with our regulations. I’m citing you.”
“We keep that door locked because the building isn’t heated and it can get quite cold in here if the door is left open,” said George.
“That might be the case,” said Tammy, “but you have to figure out another way to warm the building without limiting the ability of people to safely get out during an emergency.”
“Our employees can quickly exit the building,” said George. “We’ll fight your citation.”
Did the company win?
No. The company lost. The OSHA Review Commission refused to dismiss the citation.
The commission pointed out that employers are required to keep doors unlocked so that workers don’t need any so-called special knowledge or skills to exit a building during an emergency.
In this case, it was hard to open the deadbolt lock without detailed knowledge about how to do so. In fact, the OSHA inspector was unable to open the door until someone showed her how to do it.
The commission dismissed the employer’s argument that the door was kept closed because of the outside cold. The company needed to find another way to warm the building.
What it means: Confirm exit doors aren’t locked
Keep in mind that OSHA rules forbid employers from locking or blocking doors in such a way that people wouldn’t be able to quickly get out of a building during an emergency.
That’s why it makes sense to periodically double-check that exit doors aren’t blocked during the workday. Of course, you can close doors so that someone can’t enter from the outside without authorization. However, people on the inside have to be able to use the door without the need for a key or any special knowledge about how the door works.
Based on Secretary of Labor v. Timberline Hardwood Floors
(From the Aug. 10, 2020, issue of Safety Alert for Supervisors. To download the current issue right now, please click here.)