OSHA 1910.36: Exit Route Design and Construction Requirements for Colleges and Universities

Picture this: a fire alarm pierces the air during a packed freshman orientation in a multi-story lecture hall. Hundreds of students surge toward exits. If those paths aren't engineered right, what starts as an evacuation turns into a bottleneck nightmare. OSHA 1910.36 exists to prevent exactly that, mandating design and construction standards for exit routes that ensure safe, rapid egress in workplaces—including college campuses.

What Does OSHA 1910.36 Cover?

Under 29 CFR 1910.36, exit routes must be permanent portions of the workplace designed to provide a continuous and unobstructed path to the exterior. This standard applies broadly to general industry, which encompasses universities as employers responsible for student safety during classes, labs, and events. Key pillars include fundamental requirements for exit discharges, access, and capacity.

• Exit access: The portion leading to an exit.
• Exit: The protected enclosure to the exit discharge.
• Exit discharge: The path from the exit to a public way.

I've walked countless campus audits where overlooked details—like narrow stairwells in aging dorms—flout these rules, risking citations and worse.

Core Design and Construction Rules Tailored to Campus Life

Exit routes demand specific dimensions. Minimum width? 28 inches clear for new construction, accommodating wheelchairs under ADA synergy. For high-occupancy spots like auditoriums or gyms, calculate one exit per 100 occupants up to 500, then additional based on formulas in 1910.36(b)(1). Height must clear 7 feet 6 inches, no projections below that.

Doors play a starring role: They must swing in the exit travel direction for rooms with 50+ occupants or over 55 inches wide. No dead-end corridors exceeding 20 feet. On campuses, this hits home in chemistry labs or theaters—I've seen propped-open doors with latches that could trap people inside during hazmat incidents.

Construction-wise, exits need 2-hour fire resistance in buildings over two stories. Openings in these enclosures get 3/4-hour rated self-closing fire doors. Universities with historic buildings often struggle here; retrofits might involve sprinklers to buy time, per NFPA 101 Life Safety Code alignments.

Campus-Specific Challenges and Compliance Strategies

Colleges aren't factories, but the risks scale up. Lecture halls pack 300 souls; sports arenas hit thousands. 1910.36(g) requires exit capacity matching occupant load—divide total area by square feet per occupant (varies by use: 7 sq ft for standing rooms, 15 for classrooms). We once recalculated for a California state university's stadium: undersized gates meant evac times doubled, violating the 250 occupants per unit width rule.

Illumination and signs can't be ignored. Exits need battery-backed emergency lighting for 90 minutes, visible signs with directional arrows. In sprawling campuses, exterior exit discharges must lead to safe public areas—no dumping into loading docks or rail yards, as 1910.36(e) spells out.

Locking mechanisms? Free egress only. Panic hardware on high-occupancy doors prevents fumbling. Dorms with keycard access often trip up here—egress mustn't require keys, codes, or force during emergencies.

Common Violations and Real-World Fixes

From my experience consulting Bay Area universities, top pitfalls include:

1. Stored clutter narrowing paths—furniture in hallways.
2. Inadequate signage in multilingual student bodies.
3. Overloaded circuits dimming exit lights during drills.

Audit annually. Use tools like laser measurers for widths. Train facilities staff on 1910.147 crossovers if LOTO affects lighting. For deeper dives, reference OSHA's full 1910.36 text or NFPA 101's educational occupancy chapters. Results vary by building age and local codes, but compliance slashes injury risks by up to 40%, per CDC workplace fire data.

Actionable Next Steps for University Safety Teams

Start with a route-by-route inventory. Model evacuations via software simulating peak lecture times. Partner with EHS pros for mock drills exposing bottlenecks. Proactive design under 1910.36 doesn't just dodge fines—up to $15,625 per violation—it safeguards lives in your academic ecosystem.

Stay vigilant. Campuses evolve; so must your exits.