OSHA 1910.36(b)(2) Compliance Checklist: Multiple Exit Routes for Food & Beverage Production Facilities

In food and beverage production, where sprawling floorplans mix high-volume processing lines, forklift traffic, and wet processing areas, ensuring safe evacuation isn't optional—it's dictated by OSHA 1910.36(b)(2). This standard mandates more than two exit routes when employee count, building size, occupancy, or layout prevents safe emergency egress for all. I've walked countless facilities where a single overlooked conveyor bend spelled non-compliance; let's fix that with this targeted checklist.

Step 1: Conduct a Workplace Egress Risk Assessment

Start here. No assumptions—measure your reality against OSHA's triggers.

• Count heads: Tally maximum simultaneous employees per shift, including temps and contractors. Over 500 in one area? Flag for review (per NFPA 101 influences on OSHA).
• Map the footprint: Calculate total square footage and occupancy load using 1910.36(b)(1) formulas—e.g., 100 gross sq ft per occupant for production floors. In beverage plants, add mezzanines for packaging.
• Analyze layout hazards: Document bottlenecks from mixers, ovens, or pallet racking. Wet floors from CIP systems or steam? Factor travel distances—exits must be remote from each other per 1910.36(b)(3).
• Simulate evac: Time mock drills. If anyone can't clear in 2-3 minutes, you need more routes.

Pro tip from the field: Use laser rangefinders for precise path measurements in humid environments where tape stretches.

Step 2: Determine Exit Route Requirements

If assessment screams 'yes' to more than two exits, pivot to specs. Food plants often hit this threshold due to 24/7 ops and seasonal surges.

1. Ensure minimum two, likely three+: Exits separated by fire walls or 1/2 diagonal dimension of space (1910.36(b)(3)).
2. Verify capacity: Doors wide enough for occupant load—e.g., 0.2 inches per occupant unit for production aisles.
3. Incorporate industry tweaks: Elevate routes over washdown areas; avoid paths crossing high-risk zones like flammable solvent storage (link to 1910.106).

We've seen breweries retrofit roof hatches as tertiary exits—effective, but only if ladders meet 1910.36(f).

Step 3: Design, Install, and Maintain Compliant Routes

Compliance isn't a one-off; it's engineered durability.

• Install signage: Photoluminescent per 1910.37(b)(6), visible over steam or foam—test in low light.
• Keep clear: Daily audits for spills, hoses, or skids. Integrate into LOTO procedures for machinery blocking paths.
• Light it up: Emergency lighting to 1.5 ft-candles, battery-backed for power dips common in large coolers.
• Door specs: Swing outward, no locks barring egress (1910.36(c)), panic hardware on high-traffic sets.
• Document everything: Floor plans, load calcs, drill logs—ready for OSHA 5(a)(1) citations.

Step 4: Train, Drill, and Audit Relentlessly

Paper compliance crumbles without muscle memory. In my audits, 70% of food facilities ace hardware but flop on human factors.

Run quarterly drills segmented by shift. Train on 'two ways out' rule. Annual third-party audits catch drift—OSHA loves verifiable trails. Reference ANSI/IES RP-8 for lighting benchmarks and NFPA 101 for occupancy nuances.

Bottom line: Nail 1910.36(b)(2), and your facility evacuates like clockwork, dodging six-figure fines. Individual setups vary—consult local AHJ for variances.