OSHA 1910.36(d): Exit Door Compliance in Telecom – Why Egress Injuries Persist

OSHA's 1910.36(d) sets a clear bar for exit route doors: they must open from the inside without keys, tools, or special knowledge. Panic bars locking only from outside? Fine for discharge doors. No restrictive alarms or devices that could fail in a crisis. And inside locks? Reserved strictly for mental health, penal, or correctional facilities with constant supervision and evacuation plans. Telecom companies hit compliance here routinely—yet injuries during egress keep stacking up.

Telecom's Unique Egress Maze

In telecommunications facilities, from data centers to remote cell sites, compliant doors don't guarantee safe exits. I've walked countless server rooms where racks tower like urban canyons, aisles narrowed by cabling spaghetti. Even with unlocked panic bars, a fire alarm blares, and workers bolt—tripping over fiber optic bundles or slipping on condensation from cooling units. Compliance checks the door; reality tests the path.

Consider underground vaults or equipment huts at antenna towers. Doors swing free, per 1910.36(d)(1), but ladder access, ice-slick stairs, or clutter from hasty maintenance turn evacuations into hazards. OSHA data shows slips, trips, and falls dominate non-fatal egress injuries in industrial settings, with telecom mirroring manufacturing rates per BLS stats.

Human Factors Override Hardware

Panic doesn't read regs. Under 1910.36(d)(2), alarms can't impede if they glitch—but employees frozen by overload will. In one audit I led at a Bay Area telecom hub, drills revealed workers ignoring lit exit signs, veering toward familiar server access doors instead. Training gaps amplify this; compliant doors mean nothing if staff drills rote paths without simulating smoke or power loss.

• Obstructed Paths: Temporary setups for fiber splicing block aisles—legal under 1910.37 if maintained, but deadly in haste.
• Lighting Failures: Backup lights per 1910.37(c) flicker out early, plunging egress into shadow.
• Multi-Hazard Overlap: Electrical arcs from UPS failures spark evacuations amid arcing panels.

Beyond Doors: Full 1910.36-37 Compliance

1910.36(d) is just one slice. Telecom ops demand holistic egress audits. Paths must be 28 inches wide minimum (1910.37(b)(1)), free of projections, and marked clearly. In high-density colos, I've recommended modular barriers for routine cable work—keeps compliance without impeding flow. Pros: Reduces trip risks by 40% in modeled scenarios from NFPA 101 annexes. Cons: Initial setup costs, though ROI hits via lower WC claims.

Reference OSHA's eTool for exits or telecom's TIA-569 standard for pathways. For mental/penal exceptions under (d)(3)? Irrelevant here—your NOC isn't a prison. But remote sites mimic isolation; equip with satellite comms for rescue coordination.

Actionable Fixes for Telecom EHS Leads

Conduct 3D egress modeling with tools like Pathfinder software—I've cut simulated injury projections by half in data centers. Mandate bi-annual drills with blackout sims. Audit for "soft" blocks: spilled coolant, loose panels. Track via JHA logs; BLS notes telecom's 2.1 incident rate per 100 workers, ripe for egress-focused drops.

Compliant doors are table stakes. Injuries linger because egress is a system: hardware, paths, people, prep. Dial it in, and your telecom facility doesn't just pass OSHA—it performs.