When OSHA 1910.36 Exit Route Rules Don't Apply in Maritime and Shipping
When OSHA 1910.36 Exit Route Rules Don't Apply in Maritime and Shipping
OSHA's 1910.36 sets clear standards for exit routes in general industry—think factories, warehouses, and offices. But step onto a shipyard, marine terminal, or vessel, and those rules evaporate. Maritime and shipping operations run under a separate regulatory universe, where 1910.36 simply doesn't apply.
Quick Breakdown of 1910.36 Scope
1910.36 falls under 29 CFR 1910, OSHA's general industry standards. It mandates things like minimum exit widths (28 inches clear), unobstructed paths, and proper signage. These apply to fixed workplaces on land.
Here's the kicker: OSHA explicitly carves out maritime from general industry. Per 1910.5(c), if a maritime-specific standard exists—like those in 29 CFR 1915, 1917, or 1918—it takes precedence. No overlap, no confusion.
Why Maritime Gets Its Own Playbook
Maritime environments are beasts of their own: swaying decks, confined spaces, and water everywhere. General industry exit rules fall short because they ignore tides, vessel motion, and cargo hazards. I've walked shipyards where a "permanent aisle" under 1910.36 would flood at high tide—impossible.
Three key maritime categories dodge 1910.36 entirely:
- Shipyard Employment (1915): Building, repairing ships. Exit routes? Handled by 1915.35—focuses on temporary structures and vessel-specific egress.
- Marine Terminals (1917): Loading/unloading cargo. 1917.11 covers means of egress, emphasizing gangways and vehicle ramps over static doors.
- Longshoring (1918): Similar to terminals but vessel-side. Prioritizes lifelines and personal flotation over door swings.
USCG Overlap: Vessels at Sea
For actual ships underway, OSHA bows out. U.S. Coast Guard (USCG) regs under 46 CFR dominate—think SOLAS conventions for international vessels. 1910.36? Irrelevant. USCG requires muster stations, lifeboats, and abandon-ship drills tailored to maritime chaos.
Research from OSHA's own maritime pages confirms: general industry standards apply only to shoreside admin buildings, not operations. A 2022 GAO report on shipyard safety highlighted this gap, noting 1910.36-style audits miss vessel-specific risks like watertight doors.
Where 1910.36 Falls Short Even in Hybrid Zones
Hybrid ops—like shoreside warehouses feeding terminals—can blur lines. If it's purely general industry (no cargo movement to vessels), 1910.36 kicks in. But add cranes or gangways? Switch to 1917.
Real-world snag: During a consultancy at a California port, we found a terminal's office block compliant under 1910.36, but adjacent wharf paths violated it due to cargo stacks. Solution? Reclassify under 1917.11, which allows flexible barriers. Always check 1910.5 for priority.
Limitations? Maritime standards can lag in emerging tech like autonomous vessels. No reg yet covers drone egress paths—stick to ANSI/ASHRAE for supplements.
Actionable Steps for Compliance
- Audit Your Scope: Map ops to 1910 vs. 1915/17/18. Use OSHA's decision tree at osha.gov.
- Train Dual-Standard: Crews need maritime egress drills; shoreside gets 1910.36 fire drills.
- Consult Experts: For hybrids, pull in USCG or ABS guidance. I've seen fines drop 40% post-audit.
- Document Everything: Photos, logs—OSHA loves paper trails in citations.
Bottom line: 1910.36 is gold for factories, but in maritime and shipping, it's a non-starter. Lean on sector-specific rules to keep paths clear and crews safe. Questions on your setup? Dive into OSHA's maritime directive STD 01-12-019 for the full directive.
