OSHA 1910.36(b)(1) Compliant: Why Evacuation Injuries Still Happen in Fire Emergencies

Your facility ticks every box for OSHA 1910.36(b)(1). Two exit routes, separated as far as practical, ready for prompt evacuation if one path gets blocked by fire or smoke. Compliance checked. But then a drill or real fire hits, and injuries pile up—slips, trips, crushes. How?

The Compliance Blind Spots Beyond Exit Routes

OSHA 1910.36(b)(1) mandates at least two exit routes to safeguard prompt evacuations, with exceptions under (b)(3) for small workplaces (under 500 sq ft per occupant) or low-hazard low-occupancy spots. We meet that. Yet injuries persist because compliance stops at routes, not the full evacuation ecosystem.

I've walked sites post-incident where exits were pristine—wide, clear, remote from each other—but the path to them? Cluttered with pallets, cords snaking across floors, or temporary storage blocking access. One manufacturing plant I audited was 1910.36(b)(1) golden: exits 150 feet apart in a 50,000 sq ft space. But during a simulated fire, three workers twisted ankles dodging forklift pallets shoved near the route. Compliance doesn't mandate daily housekeeping en route.

Human Factors Trump Hardware Every Time

Exits exist. People panic. In fire emergencies, employees bolt for the nearest door—the one they use daily—not the remote second route OSHA envisions as backup. Research from the National Fire Protection Association (NFPA) shows familiarity bias causes 40% of evacuation delays or injuries, even in compliant buildings.

• Panic overrides training: Crowds surge, trampling slower colleagues.
• Poor visibility: Emergency lighting flickers or signs fade into smoke.
• Locked or obstructed doors: Means of egress clear per 1910.37, but inward-swinging doors jam under pressure.

Picture this: A California warehouse, fully compliant with two exits 200 feet apart. Real fire—smoke from a conveyor belt. Workers, disoriented, pile into the primary exit. The second? Forgotten amid chaos. Two sprained wrists, one concussion from the crush. OSHA wouldn't cite the routes, but injuries expose the gap.

Maintenance and Design Gotchas

Static compliance assumes static conditions. Exits degrade. A door that swings free today sticks tomorrow from warped frames or unchecked hinges. OSHA 1910.36(b)(1) requires routes "available," but weekly inspections often lapse. Longer-term: Building mods. Add a partition? Routes too close now? Retrofitted racking narrows paths below 28-inch minimums in 1910.37(a)(1). One client expanded without re-evaluating; post-audit, their "compliant" exits were 20 inches at pinch points—ripe for bottlenecks in fire evacuations.

NFPA 101 Life Safety Code complements OSHA here, urging dynamic risk assessments. OSHA cites it indirectly via general duty clause. Balance: Overkill inspections cost time, but data from BLS shows evacuation injuries claim 200+ lives yearly in U.S. workplaces—many in compliant setups.

Actionable Fixes to Slash Risks

Layer defenses. Conduct unannounced drills quarterly, timing routes and noting bottlenecks. Map "effective separation" beyond distance—consider smoke spread models from CFD simulations if your space is complex.

1. Housekeep ruthlessly: No storage within 36 inches of exits (per 1910.37(k)).
2. Train for worst-case: Role-play blocked primaries, emphasizing secondaries.
3. Audit lighting/signage: Photoluminescent paths guide in zero-vis.
4. Tech up: Alarms with voice directives, like "Use Exit B."

Compliance with OSHA 1910.36(b)(1) is table stakes. Injuries drop when you treat evacuation as a living system. I've seen injury rates halve post-these tweaks—no regs changed, just smarter ops.