A description of the proposed changes are as follows:

2. TITLE 8: GENERAL INDUSTRY SAFETY ORDERS
Chapter 4, Subchapter 7, Article 2,
Sections 3219 and 3225(a)
Exit Maintenance and Access
INITIAL STATEMENT OF REASONS

INFORMATIVE DIGEST OF PROPOSED ACTION/PLAIN ENGLISH OVERVIEW

Section 3219. Maintenance of Exits.
This section consists of two subsections, designated as (a) and (b). Subsection (a) requires exits to be kept free of obstructions/impediments in order to ensure instant use in case of a fire or other emergency. Subsection (b) requires all fire prevention equipment, materials, etc. to be maintained in good operating condition and that tests be made to assure they will function properly in case of fire or other emergency.

Revisions are proposed to delete the word "Exit" in the title for replacement by the phrase "…Fire Protection Equipment, Materials, and Assemblies." Board staff also proposes to relocate the requirement of subsection (a) to Section 3225 and repeal the subsection designator (b).

The proposed revisions will have no effect upon the employer or workplace operations other than to facilitate the employer’s ability to locate exit access requirements in Title 8, General Industry Safety Orders.

In addition, Board staff proposes to delete the reference to the National Fire Protection Association (NFPA) pamphlets for replacement by a reference to Title 19 regulations which address fire protection issues. The proposed revision will clearly indicate to the employer that it is necessary to conform to California Fire Code as contained in Title 19 (based upon the Uniform Fire Code) consistent with the local jurisdiction fire protection entities who enforce the California Fire Code.

Section 3225. Access to Exits.
Section 3225 contains various requirements relating to ensuring employee access to exits is free, direct, accessible and effective in providing a way for the employee to exit the work area in the event of an emergency.

Subsection (a) requires all workplace exits to be located in manner that will be accessible to the employee. This subsection also prescribes the manner in which exit access is to be provided when they are not immediately accessible from an even floor area.

Revisions are proposed to relocate the deleted requirement contained in Section 3319(a) to Section 3225(a) as new subsection (a)(1). The transferred requirements would require all exits to be maintained free of obstructions to full instant use in case of fire emergency. A further editorial revision is proposed to designate the third sentence of subsection (a) as new subsection (a)(2).

Since the proposed revisions consist of relocating and consolidation of an existing requirement with related regulatory material, the proposal will have no other effect other than to make it easier for employers to read and understand the requirements for providing employees with the necessary access in the event of a fire or other emergency.