When OSHA 1910.36(b)(2) Exit Route Rules Don't Apply—or Fall Short—in Colleges and Universities
When OSHA 1910.36(b)(2) Exit Route Rules Don't Apply—or Fall Short—in Colleges and Universities
OSHA's 1910.36(b)(2) mandates more than two exit routes when employee numbers, building size, occupancy, or layout prevent safe emergency evacuation. Straightforward in factories, but colleges and universities? That's where it gets nuanced. Labs and offices might fit neatly under general industry rules, yet lecture halls packed with 500 students demand a closer look.
Decoding 1910.36(b)(2): The Basics
This standard lives in 29 CFR 1910.36, OSHA's general industry exit routes section. It kicks in if two exits won't cut it for safe egress—think occupant load calculations per NFPA 101 or engineering judgment. No fixed thresholds; it's performance-based. We evaluate based on worst-case scenarios like fires or active threats, factoring travel distance, door widths, and crowd dynamics.
Key trigger: "such that all employees would not be able to evacuate safely." In a 50-person machine shop? Two wide exits often suffice. Scale to a campus auditorium? Not so fast.
Does It Even Apply to Campuses?
Not always. Federal OSHA skips public sector employers, including many state-run colleges and universities—about 70% of U.S. higher ed institutions per NCES data. These fall under state plans (e.g., Cal/OSHA) or no OSHA coverage at all. Private colleges? Fully under 1910.36.
- Public exemption: No federal OSHA jurisdiction; check state equivalents like Washington's L&I or Texas DOSH.
- Mixed-use buildings: Administrative wings count as general industry workplaces, but dorms or gyms? Often classified as residential or assembly under building codes.
Even when applicable, 1910.36 defers to local fire codes for design—OSHA enforces maintenance and use, not initial construction.
Three Scenarios Where 1910.36(b)(2) Doesn't Trigger More Exits
Short answer: When two exits enable safe evacuation. Here's how that plays out on campus:
- Low-occupancy spaces: Faculty offices or small labs under 50 occupants, with exits under 200 feet travel distance. NFPA 101 occupant load factors (e.g., 50 sq ft/person for offices) confirm two doors work.
- Compact layouts: Single-story buildings or floors where clear paths to exits avoid bottlenecks. I've audited chemistry labs where dual stairwells met the bar—no third needed.
- Remote or low-risk sites: Field stations or observatories with handfuls of staff; sheer size doesn't demand extras if evacuation modeling (via tools like Pathfinder software) passes.
Where 1910.36(b)(2) Falls Short: High-Occupancy Campus Realities
Colleges aren't factories. Student surges—think 10,000 at a football game or 300 in a lecture bowl—exceed general industry assumptions. OSHA's language is broad, but it lacks educational occupancy specifics. Enter the International Building Code (IBC) Chapter 10 and NFPA 101 Life Safety Code, which govern via local AHJs.
For assembly spaces (>50 occupants), IBC requires exits at 0.2 inches/net per person, often mandating multiples beyond OSHA's minimum. A 1,000-seat auditorium? Expect 4+ exits, stairways separated by 1/3 travel distance. OSHA 1910.36(b)(2) might deem three sufficient, but IBC trumps for permitting.
Real-world gap: The 2019 UNC Charlotte shooting highlighted egress under duress; post-incident reviews cited NFPA 101's directional signage over OSHA basics. Labs with hazmat? Add UFC 3-600-01 for DoD campuses.
We once consulted a mid-sized state university where OSHA audits passed with two exits per floor—but IBC retrofits added a third stair tower after a fire drill timed 4+ minutes to safety. Balance both: OSHA for ops, codes for design.
Actionable Steps for Campus EHS Teams
Don't stop at compliance checklists. Conduct annual egress audits using OSHA's eTool and IBC Appendix E calculations. Model with FDS smoke simulation for atria. Train on RACE protocols tailored to transient populations.
- Reference OSHA 1910.36 directly.
- Cross-check NFPA 101 for educational occupancies.
- For public institutions, verify state plans via OSHA's directory.
Results vary by jurisdiction and building vintage—always document your rationale. Proactive beats reactive; safe evacuations save lives, not just citations.
