OSHA 1910.36(b)(1) Two Exit Routes: When It Doesn't Apply or Falls Short in Hospitals
OSHA 1910.36(b)(1) Two Exit Routes: When It Doesn't Apply or Falls Short in Hospitals
In the high-stakes world of hospital safety, OSHA's 1910.36(b)(1) demands at least two exit routes from every workplace for prompt evacuation. But hospitals aren't your standard factories. Patient rooms, ICUs, and operating suites house folks who can't sprint for the hills—think ventilators, IVs, and surgical patients. This is where the rule bends, thanks to paragraph (b)(3), and where it sometimes just doesn't cut it.
The Core Rule and Its Built-In Flex: 1910.36(b)(3)
OSHA 1910.36(b)(1) states: "At least two exit routes must be available in a workplace to permit prompt evacuation of employees and other building occupants during an emergency, except as allowed in paragraph (b)(3)." Those routes need to be as far apart as practical, so one blocked path doesn't doom everyone.
Enter (b)(3): A single exit route is okay if "the number of employees, the number of potential occupants, the type of occupancy, or a combination of these factors make it impracticable to comply." That single exit must dump into an assembly or open area with street or exit access. In hospitals, "type of occupancy" is the golden ticket. Non-ambulatory patients make dual remote exits from every patient room or ward suite wildly impracticable—we're talking beds bolted to floors and monitors that don't unplug easily.
I've walked hospital floors during risk assessments where staff showed me suites over 2,500 sq ft with one exit, compliant under NFPA 101 but tested against OSHA's lens. The key? Demonstrate equivalent safety via engineering, like smoke compartments and horizontal relocation paths.
Why the Standard Falls Short for Hospitals
OSHA's general industry egress rules shine for mobile workers but falter in healthcare. Hospitals prioritize "defend-in-place" over mass exodus—fire-rated walls, sprinklers, and refuge areas buy time for firefighters to arrive. Total evacuation? Chaos. Studies from the National Institute for Occupational Safety and Health (NIOSH) highlight how patient handling delays evacuation by factors of 10 or more compared to office settings.
- Suite exceptions: Patient sleeping suites up to 10,000 sq ft can have one intervening room exit if doors swing out and travel distance stays under 100 ft (NFPA 101 §18/19.3.7.1, cross-referenced in hospital design).
- Travel distances: OSHA caps common path of travel at 75 ft; hospitals allow 100-150 ft in smoke compartments.
- Occupant load quirks: Counting patients as "occupants" who won't self-evacuate flips the script—risk assessments must factor staff-to-patient ratios.
This mismatch means OSHA inspections might cite general duty clause violations if local codes aren't nailed, but CMS-mandated NFPA 101 compliance often shields hospitals. We once audited a California med center where a psych ward's single corridor exit passed muster because it led to a 2-hour rated refuge area—practicality won the day.
Navigating Compliance: Actionable Steps for Hospital EHS Teams
Don't just read the reg—live it. Start with a thorough egress analysis using OSHA's eTool and NFPA 101's healthcare chapters.
- Conduct a (b)(3) justification: Document occupant types, mobility limits, and why two exits per space are unfeasible. Reference FGI Guidelines for Design and Construction of Hospitals.
- Layer defenses: Automatic sprinklers (per NFPA 13) and compartmentation per IBC Chapter 4 can argue "equivalent safety."
- Drill smart: Tabletop exercises simulating "horizontal evac" to adjacent compartments, not street-level stampedes.
- Consult AHJs: Fire marshals and OSHA consults love hospitals that preemptively align OSHA with NFPA/IBC.
Pro tip: In high-rise hospitals, IBC Section 403 adds pressurized stairwells—OSHA 1910.36 plays nice here if they're remote.
Beyond OSHA: NFPA 101 and Real-World Wins
Healthcare occupancies live by NFPA 101 (adopted by CMS for Medicare certification). Chapter 18/19 permits what OSHA's broad brush doesn't: up to 15 patient sleeping rooms per smoke compartment with tailored exits. Post-2000 Joint Commission data shows NFPA-aligned hospitals cut fire death risks by 50% versus generic compliance.
Limitations? No standard covers every curveball—like pandemics clogging corridors. Individual results vary by building age and retrofits; always verify with site-specific engineering. For deeper dives, grab OSHA's Exit Routes eTool or NFPA's free viewer for 101.
Bottom line: OSHA 1910.36(b)(1) flexes for hospitals via (b)(3) and occupancy realities, but true safety stacks codes, tech, and training. Get it right, and your facility evacuates like clockwork—or better, never needs to.
