OSHA 1910.36(a) Exit Route Compliance Checklist for Food & Beverage Production Facilities

In food and beverage plants, where steam, spills, and constant forklift traffic define the daily grind, exit routes under OSHA 1910.36(a) aren't just a checkbox—they're your lifeline during a fire fueled by flammable sanitizers or grease-laden exhausts. I've walked dozens of these facilities, from breweries to bottling lines, and seen how non-permanent partitions or propped-open doors turn escapes into traps. This checklist breaks down the basic requirements into actionable steps tailored to your wet, high-volume environments.

1910.36(a)(1): Ensure Exit Routes Are Permanent Workplace Fixtures

Permanent means built-in, not temporary setups that shift with production needs. In food processing, conveyor reroutes or seasonal pallet stacks often encroach—don't let them.

• Verify permanence: Inspect all exit paths for fixed walls, floors, and ceilings. No folding partitions, movable racks, or taped-off areas.
• Map against layouts: Compare exit routes to as-built drawings. In multi-shift ops, confirm night crews haven't improvised blockages.
• Food/bev specific: Check around high-moisture zones like washdown areas—ensure routes aren't compromised by temporary drainage barriers.
• Document: Label routes with permanent signage and update floor plans annually or post-renovation.

Get this right, and you're starting strong; I've seen audits fail here alone because a 'quick fix' pallet wall fooled no one.

1910.36(a)(2): Confirm Fire-Resistance Separation Ratings

Exits must be walled off from production areas with materials holding back flames for the required time: one hour for buildings with three or fewer stories, two hours for four or more. Beverage plants with towering silos or multi-level fermenters? Double-check those upper exits.

1. Assess building height: Count stories from street level to top occupied floor (1910.36(b) context). Under 4? One-hour rating. 4+? Two-hour.
2. Inspect materials: Test walls, doors, and ceilings for UL-listed fire ratings. In humid plants, corrosion can degrade steel—probe for rust-through.
3. Handle food-specific hazards: Ethanol vapors in distilleries or oil mists in fryers demand verified separations. No gypsum board substitutes without ratings.
4. Seal penetrations: Caulk pipes, ducts, and conduits with fire-rated sealants. Forklift door sweeps? Ensure they don't void ratings.
5. Third-party validation: Reference NFPA 80 for testing; hire certified inspectors if in-house doubts linger.

Pro tip: During my site visits, I've found two-hour-rated enclosures saving breweries from total downtime post-drill fires—invest upfront.

1910.36(a)(3): Limit and Protect Openings into Exits

Only occupant-access openings allowed—no storage closets or utility chutes spilling into exits. Every door? Self-closing fire door, auto-shuts on alarm, listed by a nationally recognized testing lab (per 1910.155(c)(3)(iv)(A) and 1910.7).

• Audit openings: Walk each exit route. Eliminate unnecessary doors/windows; protect survivors with 3-foot clearance.
• Fire door checklist: Self-closing hinges? Fusible links intact? No wedges/propped open (common in hot production lines).
• Integration test: Sound the fire alarm—doors must latch shut. In noisy bottling halls, verify employee alarm ties in seamlessly.
• Label verification: Check for 'Listed' labels from UL, FM, or Intertek. Frames/hardware included—no aftermarket swaps.
• Food/bev tweaks: Stainless steel doors resist sanitizers but must still meet ratings; avoid plastic vision panels that melt.

One overlooked latch failure in a dairy plant I consulted? Nearly cost an evacuation during a mock drill. Balance is key: compliant doors enhance safety without slowing workflows.

Run this checklist quarterly, post any layout changes, and involve your team—OSHA citations here average $15K+, but more critically, they protect lives amid your facility's unique hazards. For deeper dives, cross-reference OSHA's full eTool on exits or NFPA 101 Life Safety Code.