1910.36(d): Exit Doors Must Be Unlocked
Employers must make sure workers can open an exit route door from the inside at all times without keys, tools or special knowledge, though a panic bar that locks only from the outside is allowed on exit discharge doors. Exit doors must be free of devices or alarms that could block emergency use if they fail, with limited exceptions for mental, penal or correctional facilities.
Key takeaways
- 1910.36(d) is part of OSHA's general industry standards (29 CFR Part 1910, Subpart E).
- OSHA cited it 528 times in the last 3 years, in 524 inspections, with $1,620,880 in current penalties.
- Most citations: TN (54), NY (52), PR (51).
- Related part: 1910.36(d)(1) (498 citations).
- Free 5-minute toolbox talk for your crew below.
In this article
What this rule covers
29 CFR 1910.36(d) ("An exit door must be unlocked") is one requirement inside 1910.36 Design and construction requirements for exit routes, an OSHA general industry standard (Part 1910, Subpart E). It includes 3 sub-paragraphs. The official text below is copied word for word from the Electronic Code of Federal Regulations (eCFR). The numbers, injury cases and training on this page show how OSHA enforces it on real job sites.
Official text
(d) An exit door must be unlocked. 528 citations
(1) Employees must be able to open an exit route door from the inside at all times without keys, tools, or special knowledge. A device such as a panic bar that locks only from the outside is permitted on exit discharge doors. Open (d)(1) 498 citations
(2) Exit route doors must be free of any device or alarm that could restrict emergency use of the exit route if the device or alarm fails. Open (d)(2) 17 citations
(3) 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. 8 citations
Source: eCFR, text current as of 2026-10-15. Read all of 1910.36.
Where and how often it was cited
| Year | Citations |
|---|---|
| 2023 | 29 |
| 2024 | 201 |
| 2025 | 167 |
| 2026 | 131 |
Top states: TN (54), NY (52), PR (51), VA (28), NV (26)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| KRAFT HEINZ | MUSCATINE, IA | $110,000 |
| U.S. POSTAL SERVICE - ISANTI | ISANTI, MN | $85,116 |
| CIRCLE K STORES INC | AUSTIN, TX | $65,027 |
| VALENTI'S BAKERY LLC | PATERSON, NJ | $36,198 |
| MAVIS TIRE SUPPLY LLC | WESTLAKE, OH | $35,000 |
Free toolbox talk
A 5-minute crew talk on 1910.36(d), plus alerts when this rule changes. Free.
OSHA interpretation letters
- Exits must not be locked or obstructed. (1991-12-19)
- Electronic door opening device used with a security system. (1981-06-10)
- Security door lock system presently installed in the Research and Development building. (1981-03-12)
Related parts of this rule
- 1910.36(d)(1) 498 citations
- 1910.36(d)(2) 17 citations
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Frequently asked questions
Can an exit door be locked during work hours?
Employees must be able to open an exit route door from the inside at all times without keys, tools or special knowledge.
Are panic bars allowed?
Yes. A device such as a panic bar that locks only from the outside is permitted on exit discharge doors.
Are there any exceptions?
Only in mental, penal or correctional facilities, with supervisors continuously on duty and a plan to remove occupants during an emergency.
About this page
Sources
- 29 CFR 1910.36 (eCFR), text current as of 2026-10-15
- U.S. Department of Labor enforcement data: OSHA inspections, citations and accident records, copied nightly; data as of 2026-10-20
3-year window. Federal OSHA only; state-plan rules are not counted. Plain-language text is a summary, not legal advice; the official text controls. Black Belt Safety is not part of OSHA or the Department of Labor.