When OSHA 1910.36 Exit Route Requirements Fall Short in Hospitals
When OSHA 1910.36 Exit Route Requirements Fall Short in Hospitals
OSHA's 1910.36 sets baseline design and construction standards for exit routes in general industry workplaces, including hospitals. It mandates clear, unobstructed paths at least 28 inches wide, doors that swing in the direction of exit travel for occupant loads over 50, and no projections encroaching more than 3.5 inches into the path. Solid rules, right? But in hospitals, where patients on gurneys, IV poles, and staff rushing with equipment define daily operations, these general requirements often skim the surface.
OSHA 1910.36: Scope and Core Mandates
Under 29 CFR 1910.36, exit routes must be permanent, provide safe emergency escape, and accommodate the maximum permitted occupant load. We see this enforced across manufacturing plants and warehouses I've audited, where straightforward egress works fine. Key specs include:
- Minimum corridor width: 28 inches for new construction, 18 inches for existing.
- Maximum travel distance: Not explicitly capped here, but tied to 1910.37.
- No dead ends longer than 20 feet without alternatives.
This standard applies universally to general industry, per OSHA's preamble—hospitals included as non-exempt healthcare facilities. Yet, its broad brush doesn't account for healthcare-specific vulnerabilities.
Hospital Exemptions? Not Quite, But Nuanced Applicability
1910.36 doesn't outright exempt hospitals; it binds them as general industry sites. However, it explicitly excludes temporary structures or mobile crews under 1910.35(a). For hospitals, the real "not apply" moments arise in areas like patient rooms or OR suites governed by healthcare accreditation bodies.
OSHA itself cross-references NFPA standards in enforcement letters, deferring to NFPA 101 for life safety in healthcare occupancies. In a 2015 interpretation, OSHA clarified that while 1910.36 provides minimums, state hospital licensing or CMS conditions of participation supersede for design compliance. If your hospital chases Joint Commission accreditation, 1910.36 becomes the floor, not the ceiling.
Where 1910.36 Falls Short: Hospital Realities
Picture this: I've walked hospital corridors post-incident where a 28-inch OSHA-compliant path jammed with a single gurney, delaying evacuation. Hospitals demand wider clearances—NFPA 101 Chapter 19 requires 8 feet (96 inches) in most patient areas for two-way stretcher traffic. OSHA's 1910.36(c)(3) allows projections up to 4.5 inches at knee/waist height, fine for factories, disastrous for wheelchair navigation or crash carts.
Door swing rules? OSHA kicks in at 50 occupants, but hospitals factor patient dependency—bedridden folks can't self-evacuate. Travel distances stretch further under NFPA (150-250 feet depending on sprinklers) versus OSHA's implicit reliance on building codes. And don't get me started on horizontal exits or smoke compartments; 1910.36 barely nods to them, while NFPA mandates for phased evacuation in health care occupancies.
Research from the National Fire Protection Association underscores this gap: A 2020 NFPA report on healthcare fires showed 40% involved egress challenges unmet by general OSHA rules alone, citing mobility impairments as the killer variable.
NFPA 101 vs. OSHA 1910.36: Head-to-Head in Hospitals
| Feature | OSHA 1910.36 | NFPA 101 (Health Care) |
|---|---|---|
| Corridor Width | 28 inches min. | 8 feet min. for stretcher traffic |
| Door Swing | Outward if >50 occupants | Outward in suites >10 occupants; smoke barriers |
| Travel Distance | Not specified (ref. codes) | Up to 250 ft. with sprinklers |
| Projections/Obstructions | <4.5 inches allowed | Strictly 0-3.5 inches, accessibility-focused |
NFPA 101, enforced via CMS for Medicare-certified hospitals, fills these voids. OSHA won't cite 1910.36 violations if NFPA compliance exceeds it, per multi-agency alignments.
Practical Advice from the Field
In my audits of California hospitals, we've flagged hybrid risks: OSHA catches basic blockages, but NFPA drills into patient-centric design. Conduct a life safety survey blending both—map gurney paths, simulate evacuations with mock patients. Reference OSHA's free eTool on exit routes and NFPA's free viewer for 101 editions.
Limitations? Local AHJs (authority having jurisdiction) might tweak enforcement, and retrofits in legacy buildings vary by feasibility. Always document deviations with engineering justifications. Stay ahead: Annual drills reveal gaps no standard fully predicts.
For deeper dives, check OSHA's 1910.36 page or NFPA's 101 resources. Your hospital's safety hinges on layering these, not leaning on one.
