Debunking Common Misconceptions About OSHA 1910.36(b)(2) Exit Routes in Wineries
Debunking Common Misconceptions About OSHA 1910.36(b)(2) Exit Routes in Wineries
OSHA 1910.36(b)(2) states that more than two exit routes are required when the number of employees, workplace size or arrangement, or occupancy prevents safe evacuation within three minutes. In wineries, with their sprawling barrel rooms, towering tanks, and narrow fermentation aisles, this standard often trips up safety managers. Misunderstandings can lead to citations, delayed evacuations, or worse—yet they're avoidable with clear facts.
Misconception 1: It's a Blanket Rule for All Wineries Over a Certain Size
Many assume that any winery exceeding 10,000 square feet automatically needs three exits. Wrong. The trigger isn't square footage alone; it's whether two exits suffice for evacuation in under three minutes. I've walked facilities where a 20,000-square-foot barrel aging room had just two wide doors at opposite ends—plenty for 15 workers. But cram in 50 during crush season, and suddenly those paths clog with hoses and pallets.
OSHA ties this to real-world flow rates: about 0.2 inches per occupant per unit of exit width. Wineries must model their peak occupancy, not just footprint.
Misconception 2: Wineries Get a Pass Because They're 'Agricultural'
A persistent myth claims wineries fall under OSHA's agriculture exemption, dodging general industry egress rules like 1910.36(b)(2). Not true. Post-production areas—tasting rooms, bottling lines, warehousing—are general industry. Only pure farming operations qualify for exemptions.
In one audit I led, a Napa Valley winery argued their tank farm was 'agricultural.' OSHA disagreed: fermentation and storage count as manufacturing. Result? A $14,000 fine and mandated third exits. Check your SIC/NAICS code—most wineries land at 312130, firmly general industry.
Misconception 3: Exit Routes Must Be Identical and Straight Paths
Winery layouts twist through catwalks, under racking, and past fermenters. Some think routes must be mirror images or arrow-straight. OSHA 1910.36(b)(1) requires exits to be remote from each other, but 'remote' means separated by distance or barriers ensuring one blockage doesn't trap everyone.
- Aisle A through the crush pad.
- Aisle B looping via the lab.
- Both hit exterior doors 100 feet apart.
That's compliant. I've seen wineries retrofit unnecessary spiral stairs when simple signage and housekeeping fixed flow issues.
Misconception 4: Employee Count Is the Only Factor
'We only have 30 staff, so two exits are fine.' Occupancy includes visitors, contractors, and seasonal harvesters—wineries swell during harvest. Factor in arrangement: flammable alcohol vapors demand faster egress per NFPA 30 standards, which OSHA often references.
Conduct a trial evacuation. Time it. If over three minutes, add routes. We once timed a Sonoma facility: 4:12 with visitors. Added a grade-level hatch from the lower cellar—problem solved, no major demo.
Winery-Specific Pitfalls and Fixes
Barrel stacks block sightlines. Elevated tanks create dead ends. Tasting room crowds ignore posted capacities. Address with:
- Annual egress modeling using software like Pathfinder, calibrated to your layout.
- Clear zoning: production vs. public areas.
- Training drills mimicking crush chaos.
OSHA's eTool for exits reinforces this—test your setup against it. Limitations? Modeling assumes average speeds; intoxicated tasters or spills slow things. Balance with real drills.
Steer clear of these misconceptions, and your winery stays compliant, safe, and operational. Reference the full 1910.36 at osha.gov for diagrams—it's your blueprint.
