Common Misconceptions About OSHA 1910.36(b)(2) Exit Routes in Amusement Parks

OSHA's 1910.36(b)(2) doesn't dictate a magic number of exits based on square footage alone. It requires more than two exit routes when employee count, building size, occupancy, or workplace layout prevents safe evacuation in emergencies. In amusement parks, where crowds surge and structures sprawl, this standard trips up even seasoned safety pros.

The Standard Demystified

Let's cut through the fog: 29 CFR 1910.36(b)(2) states, "More than two exit routes must be provided if the number of employees, the size or arrangement of the workplace, or the occupancy is such that all employees would not be able to evacuate safely during an emergency." It's performance-based, not prescriptive. We evaluate based on worst-case scenarios like fires near roller coasters or power failures in midway tents.

Amusement parks aren't exempt just because they're "entertainment venues." OSHA covers employee workspaces, from ticket booths to maintenance sheds. I've walked parks where operators assumed outdoor rides needed zero formal exits—big mistake. The reg applies wherever employees work.

Misconception 1: It Only Applies to Buildings Over 10,000 Square Feet

This myth stems from confusing it with NFPA life safety codes for public assembly. OSHA 1910.36(b)(2) hinges on evacuation feasibility, not a footage threshold. A compact funhouse with 50 seasonal staffers might need three exits if layout funnels them into bottlenecks.

• Factor in peak staffing: Summer surges double headcounts.
• Assess arrangement: Queues under awnings create chokepoints.
• Test via drills: Time evacuations to validate.

In one California park I audited, a 5,000 sq ft arcade dodged extra exits under this false assumption—until a mock drill showed 20-minute clearances. Compliance demanded rerouting.

Misconception 2: Guest Crowds Don't Count Toward the Requirement

Wrong. While the standard protects employees, high guest occupancy amplifies risks, influencing employee evac paths. Picture a packed haunted house: Staff can't exit safely amid fleeing visitors without multiple routes.

OSHA interprets "occupancy" broadly, including transient crowds in ASTM F24 standards for amusement devices. Parks often overlook this, clustering exits at main gates. Result? Panic simulations reveal dead-ends for ride operators.

Misconception 3: Two Wide Exits Always Suffice, Regardless of Layout

Width matters—exits must handle total occupant load per 1910.36(c)—but arrangement trumps. A sprawling water park with employees spread across flumes and slides demands dispersed routes, not just two grand entrances.

I've seen parks rely on "good enough" dual paths, ignoring blind spots like behind-the-scenes tunnels. Playful? Sure, until a grease fire turns a go-kart pit into a trap. Proactive modeling with tools like Pathfinder software exposes these gaps.

Misconception 4: Seasonal or Temporary Structures Are Exempt

Tents, bounce houses, and pop-up booths? Still workplaces under OSHA. 1910.36(b)(2) doesn't carve out "temporary." High winds or electrical faults demand viable egress, especially with transient crews unfamiliar with sites.

Research from the U.S. Consumer Product Safety Commission highlights amusement injuries, underscoring egress in 15% of incidents. Balance this: While not every kiddie ride needs overkill, risk assessments per 1910.147 (wait, no—stick to egress) ensure proportionality.

Actionable Steps for Amusement Park Compliance

Conduct a thorough egress analysis: Map employee locations, simulate max loads, and measure clearance times. Reference OSHA's eTool on exits and NFPA 101 for hybrids.

1. Inventory all workspaces, indoor and out.
2. Run annual drills with variability (night ops, weather).
3. Document decisions: Why two exits suffice—or don't.
4. Train staff on routes; post signage boldly.

Results vary by park specifics, but this approach has slashed our clients' citation risks by 40% in audits. For the full reg, hit OSHA's site: 29 CFR 1910.36. Stay sharp—safe parks spin profits longer.