When Can a Company Be OSHA 1910.36 Compliant but Still Experience EHS Injuries?

Meeting the OSHA 1910.36 standard for exit routes is crucial for safety, but it's not a silver bullet for all EHS concerns. In my experience, I've seen companies fully compliant with this regulation yet still facing workplace injuries. This paradox highlights the complexity of safety management and the need for a holistic approach to EHS consulting.

Understanding OSHA 1910.36 Compliance

OSHA 1910.36 outlines specific requirements for the design and construction of exit routes. These include ensuring that exits are adequately lit, unobstructed, and lead directly outside or to a street, walkway, or open space with access to the outside. Compliance with these standards is non-negotiable and foundational for workplace safety.

Beyond Compliance: Where Injuries Can Still Occur

Even with perfect compliance to 1910.36, other factors can lead to injuries:

• Human Error: No regulation can prevent mistakes or lapses in judgment. For instance, an employee might ignore safety protocols during an emergency evacuation.
• Maintenance Issues: Regular maintenance is key. A compliant exit route can become hazardous if not maintained properly, like a door that gets stuck due to lack of lubrication.
• Other Hazards: Compliance with exit routes doesn't address other workplace hazards such as machinery operation, chemical exposure, or ergonomic risks.

Real-World Example

I recall working with a manufacturing plant that was 1910.36 compliant but still experienced a series of slips and falls. The root cause? Wet floors near the exit routes during certain production processes, which weren't covered by the exit route standards. We implemented additional safety measures, like slip-resistant flooring and better drainage, to address this specific issue.

Holistic EHS Consulting

To truly minimize workplace injuries, companies need a comprehensive EHS strategy. This includes:

• Regular safety audits beyond just exit routes.
• Continuous training and education for employees on all safety aspects.
• Proactive incident analysis to identify and mitigate risks across the board.

While OSHA 1910.36 compliance is essential, it's just one piece of the puzzle. A robust EHS program, supported by expert consulting, can help identify and address the myriad of other potential hazards in the workplace.