Exit violations are the cheapest citations in California to avoid and among the most common to receive, because the condition that creates them is not a decision anybody makes. It accumulates. A pallet goes down in a corridor for an hour, a cabinet gets pushed against a door during a remodel, a seasonal display goes up in front of an exit sign, and none of it was ever approved by anyone.
Accessible at all times
8 CCR section 3225(a) requires that exits be located and arranged so they are readily accessible at all times. Where exits are not immediately accessible from an open floor area, safe and continuous passageways, aisles or corridors have to lead to every exit, arranged to give each occupant at least two separate routes, except where the regulations allow a single exit or a limited dead end.
Section 3225(a)(1) is the sentence that gets cited: every exit shall be free of all obstructions or impediments to full instant use in the case of fire or other emergency. Full instant use. Not “movable in a minute.”
What an exit may not pass through
Section 3225(b) permits exits to open into adjoining rooms where those rooms are accessory to the area served and provide direct egress to a corridor, stairway or exterior exit. But exits cannot pass through kitchens, storerooms, restrooms, closets or similar spaces, and they will not pass through any room subject to locking. Foyers and lobbies meeting corridor standards are not treated as intervening rooms.
The room subject to locking is the recurring one. An exit route that runs through a storage room someone locks at night is not an exit route, and the fact that it is unlocked during business hours does not cure it.
Things that hide an exit
Section 3225(c) prohibits hangings and draperies that conceal an exit, and states that no mirrors shall be placed on exit doors or so placed as to confuse the direction of exit. Section 3225(d) requires the arrangement of exits to avoid unnecessary travel in the direction of a high hazard area unless the path is effectively shielded by suitable partitions or other physical barriers.
Signs, lighting, and devices on doors
Section 3215 requires exit paths to be lighted so they may be easily recognized, with all exit and directional signs clearly visible. It also sets the limit on hardware that restricts egress: any device or alarm installed to restrict the use of an exit has to be designed and installed so that it cannot, even in case of failure, impede or prevent emergency use of that exit.
That covers the alarmed door a retailer adds after a theft, the magnetic lock tied to an access control system, and the chain that appears after hours. The failure mode is the test. If the power goes out, or the panel faults, and the door does not open, the installation does not meet the section.
Section 3215 also states that no building or structure under construction shall be occupied in whole or in part until the exit facilities required for the occupied part are completed and ready for use. Phased occupancy during a tenant improvement is where this is most often missed.
The walk that prevents all of it
Once a month, walk each exit route from the furthest occupied point to the public way. Open every exit door. Look up at the signs and look down at the floor. Write the date, the route, and what you found — including the months you found nothing. Ten minutes. It is also the only record that shows the obstruction found on inspection day was an hour old rather than a practice.
Michael Karl McNeil — environmental health and safety, industrial hygiene, Cal/OSHA citation defense.
