This memorandum to OSHA Regional Administrators announced that the January 2009 Corporate-Wide Settlement Agreement between UPS and OSHA terminated on May 29, 2019. Rather than dropping the agreement's approach, OSHA said it would continue to use the provisions of the UPS CSA as means to enforce two exit-route standards in the courier and express delivery industry (NAICS 492110): 29 CFR 1910.36(g)(2), which requires exit access to be at least 28 inches (71.1 cm) wide at all points, and 29 CFR 1910.37(a)(3), which requires exit routes to be free and unobstructed, with no materials or equipment placed permanently or temporarily within them.
Under the enforcement approach, OSHA will generally not cite employers in NAICS 492110 if they establish and enforce written job methods covering: temporary placement (packages on one side only, leaving at least one exit path, positioned for immediate removal in an emergency); loading and unloading operations (personnel must monitor conditions and minimize impediments from packages); and a strict prohibition on obstructions directly in front of exit doors or at the tops and bottoms of stairways.
When compliance officers observe impediments to the 28-inch clearance, the memo directs them to examine the employer's relevant documentation and conduct employee interviews before deciding whether to cite.