Most Common OSHA 1910.36(e) Violations in Maritime and Shipping: Side-Hinged Exit Doors Gone Wrong

Picture this: a crowded shipyard warehouse during a shift change, alarms blaring from a minor spill. Workers bolt for the exit, only to wrestle with a sliding door that's jammed under pressure. That's the nightmare OSHA 1910.36(e) aims to prevent. This standard mandates side-hinged doors for room-to-exit connections, with outward swing required for high-occupancy spaces over 50 people or high-hazard zones like those packed with flammables or explosives common in maritime ops.

Why 1910.36(e) Hits Hard in Maritime and Shipping

Maritime environments—shipyards under 29 CFR 1915, marine terminals via 1917, and longshoring in 1918—often borrow from general industry rules like 1910.36 when specifics overlap. Crowded terminals, paint lockers, and engine repair bays scream high hazard. OSHA data from 2022 shows egress violations topping citations in shipbuilding, with 1910.36(e) frequently flagged. I've inspected ports from Long Beach to Houston where non-compliant doors turned routine drills into chaos.

These aren't abstract regs. A jammed door can trap dozens amid welding fumes or fuel vapors, escalating risks fast.

Top 5 Common OSHA 1910.36(e) Violations in the Industry

1. Sliding or Rolling Doors as Primary Exits: Ubiquitous in cargo bays and container yards for efficiency, but 1910.36(e)(1) demands side-hinged only. OSHA cited a California terminal in 2023 for using roll-up doors on a 60-person break room—fine for vehicles, fatal for evacuations.
2. Inward-Swinging Doors in High-Occupancy Areas: Warehouses holding briefings for 50+ longshoremen often have doors pushing against escape flow. Violation of 1910.36(e)(2). We see this in staging areas where "space-saving" trumps safety.
3. High-Hazard Rooms Without Outward Swing: Flammable storage lockers or grit-blasting enclosures with inward doors. Explosive risks amplify here—OSHA's inspection logs from Gulf Coast shipyards list dozens yearly.
4. Improperly Labeled or Obstructed Side-Hinged Doors: Even compliant doors fail if chained or boxed in, indirectly breaching the spirit of 1910.36(e). Maritime clutter like hoses and pallets invites this.
5. Retrofit Oversights on Converted Spaces: Old vessels repurposed as workshops get new walls without egress upgrades. A 2021 Norfolk citation hit a yard for this in a former hold turned paint shop.

Real-World Fallout: Lessons from the Docks

Back in my early consulting days, I audited a Seattle ship repair facility post-incident. A high-hazard welding bay door swung inward during a fire drill—20 workers piled up, delaying exit by 45 seconds. No injuries, but the OSHA fine was $15K, and morale tanked. Stats from OSHA's establishment search tool confirm: maritime egress citations averaged $14,502 per serious violation in 2022, with 1910.36(e) in the top tier.

Balance note: While outward doors prevent crowd crush, they demand sturdy frames to avoid wind-whip issues on open decks. Research from NFPA 101 echoes this, recommending panic hardware for reliability.

Auditing and Fixing 1910.36(e) Compliance

Start with a walkthrough: Map every room-to-exit path, count max occupants, flag hazards per NFPA 30 for flammables. Swap sliders for side-hinged steel doors rated for marine corrosion—UL-listed swing-out models run $800–$2K installed.

• Train crews quarterly on egress paths using virtual sims.
• Integrate into JHA for shipyard tasks.
• Document retrofits with photos for OSHA defense.

Pro tip: Pair with 1910.37 for full exit route audits. Tools like laser measurers speed occupancy calcs.

Resources for Deeper Dives

OSHA's 1910.36 page details enforcement. For maritime, cross-reference 1915 Shipyards. USCG's NVIC 2-93 offers vessel-specific egress guidance. Track citations via OSHA's inspection search—filter by NAICS 3366 for shipbuilding.

Stay ahead: Compliant doors aren't just regs; they're your crew's fast track out. In maritime's high-stakes rhythm, that's non-negotiable.