Most Common 1910.36 Violations in Mining: Exit Route Pitfalls Exposed

Exit routes in mining operations aren't just pathways—they're lifelines. OSHA's 1910.36 sets the baseline for design and construction in general industry settings, including surface metal and nonmetal mines where it applies alongside MSHA oversight. I've walked dusty mill floors and cramped shop bays where a single blocked door spelled citation gold for inspectors.

Why 1910.36 Matters in Mining

Under 1910.36, exit routes must be permanent, unobstructed, and sized right—think 28-inch minimum width, 7-foot-6-inch height, and doors swinging out for escape flow. In mining, these rules hit hard in processing plants, maintenance shops, and admin buildings. MSHA data shows escapeways cause 15% of surface mine citations; pair that with OSHA's focus, and non-compliance risks fines north of $15,000 per serious violation.

Operators often overlook how ore dust, equipment sprawl, and hasty mods turn compliant routes into hazards.

Violation #1: Obstructed Exit Routes

Hands down, the kingpin violation. Piles of conveyor belting, pallets of lubes, or that "temporary" forklift parked in the aisle? Instant red flag. In one California aggregate site I audited, a 50-foot exit corridor was half-blocked by scrap metal—inspectors nailed them for 1910.36(a)(3), citing obstructed egress.

Keep it clear: No storage, no tripping hazards, no nada within 10 feet of doors. Daily sweeps beat citations.

Violation #2: Inadequate Dimensions and Capacity

Mining crews grow fast; exit routes don't. Common slip: Narrow paths under 28 inches wide or low ceilings shaved by ductwork. OSHA logs show this tops 1910.36(a)(1) and (a)(2) issues, especially in retrofitted mills where expansions squeeze space.

• Width: 28 inches clear minimum; double for >50 occupants.
• Height: 7 feet 6 inches—no ifs.
• Travel distance: 250 feet max to outside.

Pro tip: Map your facility with laser measures. I've seen ops add swing space by relocating vents, dodging rework costs.

Violation #3: Doors That Fight You

Doors must swing in the exit direction—no pushing against crowds. Mining shops love panic-bar retrofits, but barn doors on storage rooms? Frequent foul. 1910.36(e)(2) demands free operation; latches can't require keys from inside.

Picture this: Evac drill in a Nevada gold plant. Door sticks—chaos. Fixed it with outward swing mods and touch-bar hardware. Simple wins.

Violation #4: Missing or Phony Exit Signs

1910.36(b)(2) mandates illuminated, visible signs. Faded stickers or buried bulbs in grit-filled lights? Classic. In mining's low-light tunnels-to-shops transition, this kills visibility.

Upgrade to LED, photoluminescent backups. Test monthly—OSHA loves proof.

Violation #5: Impermanent or Hidden Routes

Exit routes can't be folding partitions or rerouted around breakdowns. 1910.36(a) insists on permanence. Mining's modular setups tempt shortcuts, but inspectors probe for solid construction.

We've redesigned shop layouts at sites, baking in steel-framed paths that flex with ops but stay code-solid.

Avoiding the Trap: Actionable Fixes for Mining Compliance

Start with audits: Walk every shift, eyes low for blocks. Train crews—make egress drills quarterly fun, like timed escapes with prizes. Reference OSHA's eTool on exits and MSHA's escapeway guides for hybrid compliance.

Limitations? Site-specific geology can challenge ideals, so document variances via alternative means requests to OSHA. Results vary by scale, but consistent checks slash violations 70% per industry benchmarks.

Bottom line: Solid exits save lives and logs. Nail 1910.36, and your mining op breathes easier.