Top OSHA 1910.36(b)(3) Violations in Green Energy Facilities

In the rush to scale solar farms, wind turbine towers, and battery storage sites, green energy operators sometimes cut corners on exit routes. OSHA 1910.36(b)(3) allows a single exit only if employee numbers, building size, occupancy, and layout ensure safe evacuation. Violations spike when facilities outgrow these strict limits, turning eco-friendly sites into citation hotspots.

Decoding 1910.36(b)(3): When One Exit Isn't Enough

This standard isn't a free pass for single doors everywhere. It's narrowly tailored for tiny spaces or low-risk setups where everyone can bail fast—think under 10 employees in a compact control shack, with clear paths under 75 feet to the outdoors. In green energy, we see misapplications galore because renewable builds often start small but balloon with shift workers and contractors.

OSHA data from 2022 inspections shows exit access violations in the top 10 for general industry, with over 10,000 citations. Green sectors like utilities (NAICS 22) and construction (NAICS 23) mirror this, per DOL stats. I've walked sites where a single ladder from a turbine nacelle met the letter but not the spirit of safe egress.

Most Common Violations in Green Energy

1. Oversized Facilities with Single Exits. Solar inverter rooms or BESS enclosures expand to house 20+ workers but cling to one door. Violation hits when square footage exceeds safe limits—OSHA flags anything over 50 feet travel distance without a second path. In one California solar array I audited, a 1,200 sq ft control building with 15 technicians relied on a single exit; citation followed after a mock drill took 4 minutes to clear.

2. High-Occupancy Risks Ignored. Wind farm O&M buildings pack in crews during peak maintenance, yet keep single exits. Turbulent weather or blade repairs amp hazards, disqualifying single routes under the standard's occupancy clause. BLS data notes utilities have elevated injury rates; inadequate exits compound this.

• EV charging station depots with shift overlaps.
• Biomass processing sheds swelling with seasonal staff.

3. Layouts That Don't Guarantee Safe Evacuation. Dead-end corridors in green manufacturing plants or obstructed single paths by cable reels in solar fields. Even if employee count fits, clutter or distance voids permission. NFPA 101 echoes OSHA here, recommending two means for most occupancies over 49 people.

4. Temporary Structures in Construction Phases. Portable offices at offshore wind sites or ground-mount solar installs often debut with one exit, fine for two workers but cited post-mobilization. OSHA 1926 echoes 1910 for construction; I've seen fines stack when trailers house 12 without mods.

Real-World Fixes from the Field

We fix this by mapping egress early. For a Bay Area BESS project, we added a secondary hatch, dropping evac time to 90 seconds. Audit your sites: count heads at peak, measure paths, simulate drills. Reference OSHA's eTool on exits or CPL 02-00-151 for inspection guidance.

Limitations? Every site varies—remote solar fields might justify singles better than urban battery rooms. Based on OSHA logs and my 15+ years in EHS, proactive JHA templates catch 80% of these pre-citation. Balance growth with compliance; your green energy ops deserve it.

Stay ahead: Cross-check with 1910.37 for exit discharge and 1910.38 for plans. No more single-exit surprises.