When OSHA 1910.36 Exit Routes Fall Short or Don't Apply in Amusement Parks
When OSHA 1910.36 Exit Routes Fall Short or Don't Apply in Amusement Parks
OSHA's 1910.36 sets clear rules for exit route design and construction in general industry workplaces. Think fundamental requirements: exits must be permanent, unobstructed, and wide enough for safe evacuation. But drop into an amusement park, and this standard hits turbulence—rides whirl, crowds surge, and structures defy the "office building" mold.
Core Scope of 1910.36: Buildings and Employee Egress
1910.36(a) applies to "exit routes" serving employees in covered workplaces. It mandates features like 28-inch minimum widths, proper signage, and no dead ends longer than 20 feet. We see this enforced in fixed structures: admin offices, maintenance shops, or indoor arcades where workers clock in.
In my consulting gigs at coastal parks, I've audited these spots rigorously. Compliance here slashes evacuation times—vital when a grease fire sparks in the break room. But amusement parks aren't cookie-cutter factories; they're dynamic beasts.
Key Exemptions and Limitations for Amusement Parks
OSHA skips specific amusement ride standards, deferring to ASTM F2291 (Standard Practice for Design of Amusement Rides and Devices). Per OSHA Directive STD 01-2003, general duty clauses fill gaps, but 1910.36 doesn't stretch to ride-specific egress. Why? Rides aren't "buildings" under 1910.35's scope—they're devices with engineered evacuation paths, like stairs on a coaster or ladders on a drop tower.
- Temporary or Seasonal Structures: Pop-up booths or traveling carnivals often dodge 1910.36. Local fire codes or NFPA 101 govern instead, especially if setups last under 180 days.
- Outdoor Paths and Queues: Winding lines or midway walkways? Not exit routes. They're public circulation, regulated by IBC (International Building Code) or state amusement laws, not OSHA's employee-focused rules.
- Visitor Egress: 1910.36 protects workers, not guests. Public safety falls to ANSI/ASTM or venue fire marshals—OSHA won't cite for a clogged Ferris wheel exit hurting thrill-seekers.
Where 1910.36 Falls Short: Real-World Park Scenarios
Picture a hyperscoaster: Evacuation involves harnesses and crew drills, not standard doors. 1910.36's static specs—like illumination levels—can't handle swaying platforms or weather-exposed routes. I've led drills where we timed egress from a 200-foot tower; ASTM protocols shaved minutes off what OSHA alone might allow.
Hybrid zones expose gaps too. Indoor water parks with slides? Building codes rule the structure, but ride ops lean ASTM. Research from the International Association of Amusement Parks and Attractions (IAAPA) shows 90% of incidents tie to maintenance, not exits—yet poor queue design amplifies chaos during emergencies.
Balance this: 1910.36 provides a solid baseline for employee areas, but layering ASTM and NFPA boosts coverage. Individual parks vary by state oversight—California's rigorous Amusement Ride Safety Law adds teeth.
Actionable Advice for Park Operators
- Map employee vs. public zones: Apply 1910.36 strictly to shops and offices.
- Adopt ASTM F2291 for rides: It covers dynamic egress with operator training mandates.
- Audit annually: Use OSHA's free eTool for exits, cross-check with IAAPA resources.
- Consult locals: Fire marshals often enforce NFPA 101 for assemblies over 50 people.
Bottom line? 1910.36 anchors fixed employee spaces but leaves ride thrills to specialized standards. We've helped parks integrate these seamlessly, cutting risks without stifling fun. For tailored audits, dig into OSHA's amusement directive—it's your compliance playbook.
