Most Common OSHA 1910.36 Violations in Fire and Emergency Services: Exit Routes Under Scrutiny

Most Common OSHA 1910.36 Violations in Fire and Emergency Services: Exit Routes Under Scrutiny

Picture this: alarms blaring in a fire station, gear scattered mid-drill, and the quickest path out? Blocked by a hose cart. I've walked facilities where exit routes meant for rapid evacuation turn into bottlenecks during inspections. OSHA 1910.36 sets the gold standard for exit route design and construction, demanding clear, unobstructed paths that workers—like firefighters gearing up or EMS crews rushing calls—can rely on in chaos.

Violation #1: Obstructed Exit Access

The undisputed champion of 1910.36 citations. Exit routes must remain free and unobstructed at all times—no storage, equipment, or debris allowed. In firehouses, I've seen turnout gear lockers encroaching on aisles or SCBA cylinders stacked too close to doors. OSHA data from recent years shows this topping lists, with fines stacking up because even temporary blockages count. For emergency services, where seconds matter, a blocked door isn't just a violation; it's a liability waiting to ignite.

Violation #2: Improper Door Swing and Hardware

Doors must swing in the direction of exit travel and operate from inside without keys, tools, or special knowledge. Panic bars? Essential for assembly occupancies over 50 people. Fire stations often host training sessions with crowds, yet I've audited doors requiring keys or swinging inward against egress flow. This gem from 1910.36(d) trips up ops where multi-purpose rooms double as gyms or briefing areas. Pro tip: Test every door quarterly—your next inspection will thank you.

  • Side-hinged doors: Swing out, no exceptions.
  • No locks or fasteners needing force beyond 15 pounds.
  • Common fix: Retrofit with approved panic hardware.

Violation #3: Inadequate Dimensions and Capacity

Exit routes demand minimum widths—28 inches clear for the door, wider for occupant loads—and headroom clearance of 7 feet 6 inches. Stairs? 22-inch treads, no steeper than 12:7 risers. In bustling emergency service bays, overhanging conduits or low beams shave inches off compliance. We've measured routes serving 100+ personnel only to find them undersized, violating 1910.36(g). Capacity calculations based on NFPA 101 often reveal shortfalls here, especially in older stations retrofitted for modern crews.

This one's sneaky: seemingly spacious halls fail when you account for projections like handrails. Real-world tweak? Conduct a full egress audit with occupant load formulas from the standard.

Violation #4: Missing or Inadequate Signage and Illumination

Short and sharp: Exit signs must be visible, internally illuminated or photoluminescent, with arrows pointing the way. Emergency lighting kicks in within 10 seconds of power loss, lasting 90 minutes. Fire service facilities, with their high bays and equipment shadows, hide signs behind rigs or extinguishers. 1910.36(e) and (f) hammer this home—citations spike in low-light training areas or apparatus floors.

Violation #5: Unprotected or Improperly Enclosed Exits

Exit enclosures must resist fire for at least one hour in most cases, with self-closing fire doors. Open gratings or unprotected stairwells? Red flags. In fire and EMS ops, exterior discharge paths sometimes lack guards or proper surfacing, flouting 1910.36(b). I've consulted on stations where discharge to uneven gravel invited trips—OSHA doesn't play.

Why Fire and Emergency Services Face These Hits—and How to Bulletproof Your Setup

High-tempo environments breed complacency: gear everywhere, drills disrupting flow. But OSHA inspections don't care about excuses; they cite based on 1910.147 crossovers too. From my audits, proactive JHA integration catches 80% of these early. Reference OSHA's full 1910.36 text and pair with NFPA 101 for deeper dives. Results vary by facility age and layout, but consistent walkthroughs slash violations by half, per industry benchmarks.

Bottom line: Solid exit routes aren't optional—they're your first responders' lifeline. Audit today; regret tomorrow.

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