Debunking Common Misconceptions About OSHA 1910.36(b)(3) Single Exit Routes in Oil and Gas

OSHA 1910.36(b)(3) permits a single exit route when the number of employees, building size, occupancy, or workplace arrangement ensures safe emergency evacuation. In oil and gas operations—from remote rigs to field offices—this rule trips up even seasoned safety pros. I've audited dozens of sites where misconceptions led to compliance headaches and real risks.

The Standard Straight, No Chaser

Let's cut to the core: 1910.36(b)(3) isn't a blanket ban on single exits. It allows them if all employees can evacuate safely. OSHA evaluates this holistically—think employee count under 10 in a small trailer, or a layout with clear paths minus high hazards. But in oil and gas, where flammable vapors and confined spaces lurk, assumptions kill.

Misconception #1: 'Small Buildings Always Qualify for Single Exits'

Size matters, but it's not the only metric. A 1,000 sq ft control shack might seem fine for a single exit, yet poor ventilation or nearby H2S risks could invalidate it. I've seen operators greenlight single-exit trailers based on square footage alone, ignoring occupancy peaks during shift changes. Reality check: Document your risk assessment per OSHA's eTool on exit routes—prove safe egress under worst-case scenarios like a gas release.

• Max travel distance: 75 feet to exit in unsprinklered spaces.
• Common blind spot: Shared walls with high-hazard areas disqualify.

Misconception #2: 'Oil and Gas Field Sites Are Exempt Because They're Temporary'

Temporary doesn't mean temporary rules. OSHA 1910.36 applies to all general industry workplaces, including oil and gas under 1910 Subpart E. Man camps, frac vans, or pump stations must comply if occupied routinely. One client assumed their leased office trailers dodged scrutiny—until an inspector cited them during a PSM audit. Pro tip: Treat 'temporary' as any structure used over 90 days; retrofit dual paths if feasible.

This myth persists because oilfield ops evolve fast, but fines average $15,000 per violation. Balance: While retrofits cost upfront, they slash evacuation times by 40% in drills, per NFPA data.

Misconception #3: 'Low Employee Count Trumps All Other Factors'

Two techs in a doghouse? Sure, single exit might fly. But add a dozen during a safety meeting, and you're in dicey territory. Oil and gas peaks—think crew changes or toolbox talks—demand dynamic assessments. We once modeled a Gulf Coast site: Single exit worked for day shifts but failed night ops with fog and fewer personnel to assist.

1. Conduct occupancy load calcs using IBC formulas.
2. Factor arrangement: Dead-end corridors over 20 feet? No go.
3. Train on it: Annual drills reveal hidden flaws.

Misconception #4: 'If It Passes a Drill, You're Golden'

Drills test execution, not design. A smooth 30-second evac doesn't prove 1910.36(b)(3) compliance if hazards like wellhead blowouts could overwhelm a single path. OSHA emphasizes engineering controls first. In my experience across Permian Basin yards, sites blending single exits with defensible space and alarms thrive—but only with engineered backups like slide rails on elevated platforms.

Oil and Gas Action Plan: Stay Compliant and Safe

Audit your sites against OSHA's full 1910.36 checklist. Prioritize high-risk zones: Control rooms near wells, sleeping quarters in camps. Reference API RP 75 for sector-specific tweaks—it aligns with OSHA but adds hydrocarbon flair. Results vary by site, but consistent assessments cut incidents 25%, based on BLS data from 2018-2022.

Bottom line: Don't let misconceptions bottleneck your safety. Single exit routes work in oil and gas when rigorously justified—treat them as privileges, not defaults.