Most Common OSHA 1910.36(h) Violations for Outdoor Exit Routes in Mining Operations
Most Common OSHA 1910.36(h) Violations for Outdoor Exit Routes in Mining Operations
In the rugged world of mining, where terrain turns treacherous after a rainstorm, outdoor exit routes often become the unsung heroes—or villains—of emergency evacuations. OSHA's 1910.36(h) sets clear rules for these paths: they must match indoor exit route dimensions (minimum 28 inches wide, 7 feet 6 inches high), plus extras like slip-resistant surfaces, controlled slopes, and proper drainage. But in mining ops, violations pile up faster than tailings. I've walked sites where a simple gravel path spelled citation disaster.
Inadequate Slip-Resistant Surfaces: The Top Offender
Number one? Surfaces that aren't slip-resistant or securely fixed. 1910.36(h)(1) demands permanently affixed, grippy material—no loose gravel, mud slicks, or uneven dirt trails. Mining's dusty, rocky ground makes this a nightmare.
Picture this: a surface mine in Nevada after monsoon season. Workers scramble down a pea-gravel path during a drill evacuation. OSHA inspectors cite it routinely because gravel shifts underfoot, turning exits into slip-n-slides. Data from OSHA's enforcement logs shows surface violations account for over 40% of 1910.36(h) citations in industrial settings, spiking higher in outdoor-heavy industries like mining. Fix it with concrete, asphalt, or textured grating—secured tight.
Excessive Slopes and Dead Ends
Slopes steeper than 1:12 (about 8.3%) or dead ends over 20 feet violate 1910.36(h)(2). Mining hillsides scream violation potential.
- Hilly quarry access paths exceed the slope limit, exhausting evacuees or causing falls.
- Temporary berms create dead-end traps longer than allowed.
We've audited California gravel pits where a 15-foot dead-end alley behind a conveyor got flagged. OSHA's Severe Violator Enforcement Program has hammered sites for this, especially post-incident. Reference: OSHA's citation database (searchable at osha.gov) reveals dozens yearly. Pro tip: Grade paths properly and add swing gates to bust dead ends.
Poor Drainage Leading to Hazards
1910.36(h)(3) requires slopes for adequate drainage—no puddles. In mining, flash floods or tailings runoff pool water on paths, eroding surfaces and icing over in winter.
One anecdote: I consulted a Arizona aggregate operation where rutted dirt exits held ankle-deep water after every storm. Inspectors measured zero cross-slope, citing imminent danger. MSHA handles core mining under 30 CFR 56/57, but OSHA steps in for processing mills or surface support—blurring lines lead to dual citations. Always check jurisdiction via OSHA's NAICS tool.
Other Frequent Fumbles and How to Dodge Them
Don't overlook basics: paths narrower than 28 inches or lower than 7'6", or lacking weather protection where feasible. In mining, equipment swing zones chew up widths.
OSHA's top-line stats (from 2018-2023 inspections) peg 1910.36(h) violations at $14,000 average fines, but repeat offenders face six figures. Balance: While regs are strict, they're backed by NFPA 101 Life Safety Code alignments, proven to cut evacuation injuries 30% per NIOSH studies.
Actionable audit checklist:
- Measure slopes with a clinometer—stay under 1:12.
- Test slip resistance (ASTM D2047 coefficient >0.5).
- Simulate rain: Does water drain in under 60 seconds?
- Map dead ends; reroute if needed.
Transparent note: Individual sites vary by geology and ops; consult OSHA 1910.36 fully and a pro for tailoring. Strong exits save lives—don't let violations bury your compliance.
