OSHA 1910.36(b)(1) Compliant: Why Maritime and Shipping Ops Still See Evacuation Injuries

Picture this: a loading dock in Long Beach, two clearly marked exit routes spaced 50 feet apart, doors swinging free, no obstructions. Your team checks the boxes for OSHA 1910.36(b)(1)—at least two exit routes, far enough apart to dodge a single-point failure from fire or smoke. Compliant on paper. Yet, injuries pile up during drills or real emergencies in maritime and shipping. How? Compliance is the floor, not the ceiling, especially in the chaotic world of vessels, cranes, and cargo seas.

The Maritime Twist on Exit Routes

OSHA 1910.36 governs general industry, demanding those dual exits for prompt evacuations. But maritime falls under 29 CFR 1917 (Marine Terminals), 1918 (Longshoring), and 1915 (Shipyards). These layers add vessel-specific mandates—like 1917.122 for egress from buildings on terminals—that 1910.36 alone doesn't touch. A company might nail general industry compliance but miss shipboard gangways shifting with tides or cargo stacks blocking secondary paths mid-load.

I've walked enough piers from Oakland to San Diego to know: one rogue container swing, and your "far as practical" exits turn into bottlenecks.

Common Pitfalls: Compliant Routes, Injured Workers

1. Dynamic Blockages Beyond Fire/Smoke: 1910.36(b)(1) focuses on fire or smoke blocking one route. In shipping, think forklifts jackknifing across paths, loose lashings tumbling, or high winds slamming hatches shut. We saw this in a 2022 incident report from the US Coast Guard—compliant dock layout, but a pallet avalanche trapped three longshoremen.
2. No Integration with Maritime-Specific Egress: Paragraph (b)(3) exceptions allow single exits for small spaces (<75 ft travel distance), but vessels demand more. 1918.92 requires safe access/egress on ships; ignore it, and your two general exits lead straight into a heaving deck hazard.
3. Human Factors Trump Hardware: Routes exist, but untrained crews panic. Research from the National Institute for Occupational Safety and Health (NIOSH) shows 40% of maritime evac injuries stem from slips on wet gangways or overcrowding—not blocked exits. I've consulted sites where drills revealed workers defaulting to the "familiar" route, ignoring the secondary.

Short story: a San Pedro terminal we audited had pristine 1910.36 signage. During a simulated crane tip-over, half the team clustered at the primary exit, spraining ankles in the pile-up. Compliance met; readiness not.

Bridging the Gap: Actionable Steps for Maritime Resilience

Start with hybrid audits. Layer 1910.36 onto maritime standards—map exits against 1917.112 (lighting) and 1918.51 (walkways). Use Job Hazard Analyses (JHAs) to simulate shipping-unique scenarios: rogue waves, fumigated holds, or ammonia leaks from reefers.

• Install dynamic signage: glow-in-dark arrows that activate on alarms.
• Drill relentlessly: weekly, scenario-based, tracking participation via digital logs.
• Tech up: Sensors for real-time blockage alerts, integrated with incident tracking systems.

OSHA data from 2018-2023 logs over 150 maritime egress injuries despite rising compliance rates. Why? Static rules vs. fluid environments. Balance this by referencing USCG Maritime Safety Alerts (like 2021-015 on gangway failures) and NIOSH FACE reports for vessel evacuations.

The Bottom Line

1910.36(b)(1) compliance buys you a ticket to the game, but in maritime and shipping, you need the full playbook. Injuries persist when routes are treated as checkboxes, not lifelines amid cranes and currents. We've turned this around for West Coast ops by blending regs with real-world grit—fewer sprains, zero fatalities. Your move: audit today, evacuate tomorrow.