Common Misconceptions About OSHA 1910.36(b)(3): Single Exit Routes in Construction

OSHA's 1910.36(b)(3) allows a single exit route in general industry settings when employee numbers, building size, occupancy, or workplace layout ensure safe emergency evacuation. But in construction, where sites evolve daily and temporary structures dominate, this rule sparks confusion. Workers and supervisors often misapply it, risking citations and real hazards.

Misconception 1: Single Exits Are Never Allowed on Construction Sites

Many believe OSHA bans single exits outright in construction. Wrong. While 1926.34 governs construction egress—mandating unobstructed paths—1910.36 applies to fixed general industry buildings under construction or renovation. We've seen sites where a single exit served a small, isolated welding booth with five workers and 50-foot travel distances. It complied because evacuation was feasible.

OSHA interpretations clarify: temporary construction areas can mirror 1910.36 if they mimic general industry setups. Don't assume blanket prohibition; assess site-specific risks.

Misconception 2: It's All About Employee Count—10 or Fewer Means You're Good

Employee numbers matter, but they're not the sole factor. The standard weighs them alongside size, occupancy, and layout. A 20-employee construction office in a 5,000 sq ft single-story building might qualify if paths are straight and short. But cram 10 into a multi-level scaffold tower? No dice—congestion kills safe egress.

• Key factors from OSHA: Common path of travel under 75 feet in new buildings (NFPA 101 influence).
• Low-hazard occupancy like admin trailers versus high-risk fab shops.
• We've audited sites where 'low count' excused poor layout, leading to near-misses during drills.

Misconception 3: Construction's 'Temporary' Status Overrides the Rule

Temporary doesn't mean exempt. Construction sites lasting over a year—or fixed elements like trailers—fall under scrutiny. OSHA's 1926.34 requires 'adequate' egress, often aligning with 1910.36 criteria. I recall a California project where a single-exit shanty housed tools; it passed because dead-end corridors were under 50 feet and fire risks minimal.

Yet, pitfalls abound. Portable buildings shift, but blocked paths from materials void compliance. Balance this: pros of single exits include simpler setups on remote sites; cons involve evacuation delays if one path clogs.

Misconception 4: No Need for Documentation or Drills

Approval isn't automatic. Prove safe evacuation via risk assessments, floor plans, and drills. OSHA expects evidence during inspections—lack thereof invites violations up to $15,625 per serious infraction (2023 rates).

Pro tip: Map travel times. In one audit, a single-exit zone evacuated in 90 seconds for 8 workers—well under NFPA's 2-3 minute benchmark. Use tools like OSHA's eTool for egress or NFPA 101 for deeper dives.

Actionable Steps for Construction Compliance

1. Conduct site-specific egress audits weekly.
2. Train crews on 1910.36(b)(3) nuances via toolbox talks.
3. Reference OSHA Directive STD 1-12-3 for single-exit examples.
4. For borderline cases, consult local AHJ—results vary by jurisdiction.

Bottom line: 1910.36(b)(3) isn't a loophole; it's a calculated allowance. In construction's chaos, smart application prevents disasters. Stay vigilant—safe sites build legacies.