OSHA 1910.36(b)(1): Two Exit Routes in Trucking Facilities – What It Means and How to Comply

OSHA's 1910.36(b)(1) mandates at least two exit routes in workplaces to enable swift evacuation during emergencies. These routes must be positioned as far apart as practical, ensuring one remains viable if fire or smoke blocks the other. In trucking operations, where warehouses, loading docks, and maintenance bays dominate, this rule prevents chaos when seconds count.

Breaking Down 1910.36(b)(1) for Transportation Pros

The standard states: "At least two exit routes must be available... except as allowed in paragraph (b)(3)." Exceptions under (b)(3) apply to buildings with fewer than 10 occupants or low-hazard areas under 1,000 sq ft, but trucking facilities rarely qualify—think sprawling terminals handling hazmat loads.

I've walked trucking yards where a single blocked door spelled disaster. Picture a 50,000 sq ft warehouse: trailers parked tight, forklifts zipping, and pallets stacked high. If smoke from a forklift battery fire clogs one aisle, workers need that second path clear to the exterior.

Trucking-Specific Challenges with Exit Routes

In transportation hubs, exit routes face unique hurdles. Loading docks often create chokepoints; parked semis can block secondary paths. Maintenance shops with flammable fuels amplify risks, demanding routes separated by at least half the building's diagonal dimension per OSHA guidance.

• Narrow bays: Doors too close together fail the "far as practical" test.
• Trailer congestion: Designated no-parking zones around exits are non-negotiable.
• Multi-level dispatch offices: Stairs and ramps must lead to distinct exterior discharges.

OSHA ties this to NFPA 101 Life Safety Code principles, emphasizing separation to mitigate single-point failures. Research from the National Fire Protection Association shows facilities with compliant dual routes cut evacuation times by up to 40% in simulated warehouse fires.

Real-World Trucking Violations and Fixes

Consider a California terminal I audited: one exit buried behind propane tanks, the other 20 feet away. Citation? Immediate. We relocated tanks and widened the second path, adding signage for good measure.

Common pitfalls include storage encroaching on routes or ignoring seasonal changes—like snow drifts blocking northern exits in Midwest yards. FMCSA audits often flag these alongside OSHA, as safe facilities support DOT compliance. To fix: Map routes using OSHA's eTool, measure separations, and drill quarterly.

Actionable Steps for Trucking Compliance

1. Assess your layout: Use floor plans to verify two routes, separated maximally.
2. Clear obstructions: Enforce 28-inch minimum width, free of clutter.
3. Train relentlessly: Conduct mock evacuations, timing routes to under 3 minutes.
4. Document everything: Photos, maps, and logs shield you in inspections.

While perfect compliance slashes risks, variables like building age or layout limit ideals—always consult site-specific engineering. OSHA's free compliance assistance beats fines starting at $16,131 per violation (2024 rates).

Why It Matters for Your Operation

Trucking isn't just about miles logged; it's lives protected. Dual exit routes under 1910.36(b)(1) turn potential tragedies into orderly exits. Dive into OSHA's full standard at osha.gov or NFPA resources for templates. Stay ahead—your crew deserves it.