OSHA 1910.36: Exit Route Design and Construction in Pharmaceutical Manufacturing

Picture this: a pharmaceutical plant humming with activity, technicians in cleanroom suits navigating sterile corridors filled with high-value biologics and volatile solvents. Suddenly, an alarm blares. Chaos looms if exit routes aren't up to snuff. OSHA 1910.36 ensures those paths stay clear, safe, and compliant—no matter the high-stakes environment of pharma manufacturing.

The Core of 1910.36: Fundamental Exit Route Requirements

OSHA 1910.36(a) lays down the basics. Exit routes must be permanent parts of the workplace, designed to provide a safe path from any point to the outside. In pharmaceutical facilities, this means no temporary setups or paths blocked by production equipment like bioreactors or filling lines.

Height and width matter. Routes need at least 7 feet 6 inches of vertical clearance and 28 inches of clear width at all points—per 1910.36(b). Floors can't have projections more than 1/4 inch, and changes in elevation must be marked. I've walked countless pharma floors where overlooked floor drains or raised thresholds tripped up inspections.

Doors That Deliver: 1910.36 Exit Route Door Specs

Doors are the gatekeepers. Under 1910.36(e), they must swing in the direction of exit travel if serving 50+ occupants. No locking from inside except for specific panic hardware. In cleanrooms, where airlocks and interlocking doors maintain pressure differentials, this gets tricky. We can't compromise sterility, but exits must open freely during emergencies.

• Clear markings: Every exit door needs illuminated "Exit" signs visible from 100 feet—1910.36(f).
• No obstructions: Doors can't reduce the route width below 28 inches when open 90 degrees.
• Pharma twist: Avoid doors that require gowning room keys or badges; integrate fail-safe overrides.

One plant I audited had airlock doors that latched too securely, violating egress. Retrofitting with electromagnetic locks tied to fire alarms fixed it—compliance and safety in one swing.

Capacity and Arrangement in Pharma Plants

1910.36(g) demands exit routes accommodate occupant load without overcrowding. Calculate based on square footage: 200 gross sq ft per person for most areas, tighter for high-hazard zones like solvent storage. Pharma manufacturing often features high-hazard classifications due to flammables (think ethanol in extraction suites) or toxics.

Routes can't dead-end or pass through high-hazard areas unless protected. In multi-story facilities with mezzanines for QC labs, stairs must be enclosed with 2-hour fire-rated walls if over certain heights—cross-reference 1910.36(d). Elevators? Never count them as exits.

Pharma-specific headaches include HVAC systems blocking paths or conveyor systems in packaging lines. Solution: Dedicated, unobstructed corridors parallel to production flows. Based on NFPA 101 alignments OSHA references, aim for two exits per area serving 500+ occupants.

Outdoor Exit Routes and Pharma Perils

1910.36(h) covers exterior paths: 44-inch width min, slopes ≤1:12, protected from weather. In California pharma hubs like the Bay Area, fog and rain test these setups. Slippery walkways from chemical spills? Non-slip surfaces are non-negotiable.

Pro tip: Integrate spill containment that doesn't impede flow. I've seen loading docks double as exits—fine if graded properly and free of forklift traffic.

Common Pitfalls and Actionable Fixes for Pharma Compliance

Overloaded cleanroom antechambers often squeeze routes below 28 inches. Fix: Modular panels for wider doors without breaching ISO standards.

1. Audit annually: Map routes against occupant loads using OSHA's eTool.
2. Train staff: Drills revealing blocked paths from carts or pallets.
3. Tech up: Sensors for real-time obstruction alerts, tied to LOTO if equipment encroaches.

Research from OSHA's Severe Violator Enforcement Program shows exit route citations rack up fines—up to $15K+ per willful violation. But balanced view: Proper design cuts evacuation times by 30-50%, per NIST fire modeling studies. Individual results vary by facility layout.

Resources for Deeper Dives

Grab OSHA's full 1910.36 text here. Cross-check with NFPA 101 Life Safety Code for pharma nuances. For hands-on help, consult pros who've navigated FDA cGMP alongside OSHA.

Exit routes aren't just regs—they're lifelines. Design them right, and your pharma ops stay smooth, safe, and inspector-approved.