OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

June 10, 1981

Mr. William B. Reitze
Vice President
Chief Environmental Scientist Health,
Safety and Environment Department
Johns-Manville Sales Corporation
Ken-Caryl Ranch
Denver, Colorado 80217

Dear Mr. Reitze:

This is in response to your inquiry of May 21, 1981, concerning an electronic door opening device used with a security system.

The installation of treadle pads in front of exit doors which release the security lock as soon as the employee steps upon the treadle appears to comply with 29 CFR [1910.36(d)(2)], provided the treadle pad system will open during a power failure or the locks will open during a power failure. However, the Occupational Safety and Health Act of 1970 contains no provisions allowing approval or endorsement of equipment. Alteration or misapplication of an otherwise safe piece of equipment could easily create a hazardous condition beyond the control of the manufacturer. For this reason, the compliance of a door opening system can only be determined by the safety and health professionals observing it actually in use under specific conditions.

If we may be of further assistance, please call or write.

Sincerely,


John K. Barto Chief,
Division of Occupational Safety Programming

[Corrected 2/6/2004]