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Food plant exit doors sealed with a bolt

Summary An OSHA regional administrator reported that a food plant had replaced a padlock on an exit door with a bolt and breakable wire seal. The memo said the door still failed OSHA's exit requirements because workers had to remove the bolt before opening it, even though a USDA inspector had allowed the seal. The region asked OSHA to alert USDA inspectors to the issue at other facilities.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-12-19
Date issued
December 19, 1991
Status
Archived by the agency
OSHA labels this an archive document that may no longer represent its policy; it does not identify a replacement on this page.
Status last verified October 10, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

December 19, 1991

MEMORANDUM FOR: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMMING

FROM: LINDA R. ANKU
REGIONAL ADMINISTRATOR

SUBJECT: OBSTRUCTED EXIT PERMITTED BY USDA

The purpose of this memorandum is to bring to your attention an incident that may indicate that some USDA inspectors are permitting means of egress to be obstructed based on a requirement that certain doors be "sealed". The doors are "sealed" to prevent contamination of the food. As a result of the fire in North Carolina, USDA inspectors were instructed to insure that "sealed" doors were not padlocked. An employer that had a padlock on a "sealed" door, that was an exit, was required to remove it by a USDA inspector but was permitted to insert a bolt through the hasp where the padlock had been. The bolt would have had to be manually removed before the door could be opened.
The bolt inserted through the hasp had a hole in it through which a wire was run. The wire could only be removed if it was broken, which would indicate that the "sealed" door had been opened. The USDA inspector did not realize that the method used to seal the door was still not in compliance with OSHA regulations as he only had been instructed to insure that such doors were not padlocked.
The USDA was contacted and advised of the problem and they took immediate steps to have it corrected. However, the incident raises serious concerns as to whether this is occurring at other USDA regulated facilities. The USDA representative indicated that they are to receive safety training from OSHA in the near future but until then there could be a problem with obstructed exits. We would suggest that consideration be given to immediately contacting the USDA and urging them to advise their inspectors as to what constitutes an obstructed exit.
This incident occurred at:

M.H.B. Inc. dba Harrisons Meatpacking
1207 Almond Street
Williamsport, Pa. 17702

If you need any additional information regarding the preceding, please contact John McFee at FTS 596-1201.

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