OSHA 1910.36(f): Exit Route Capacity Rules for Oil and Gas Operations
OSHA 1910.36(f): Exit Route Capacity Rules for Oil and Gas Operations
In oil and gas facilities—from offshore platforms to sprawling refineries—egress paths can mean the difference between a safe evacuation and catastrophe. OSHA 1910.36(f) zeroes in on exit route capacity, mandating that these paths handle the maximum occupant load without bottlenecks. Let's break down 1910.36(f)(1) and (f)(2), with real-world ties to your operations.
1910.36(f)(1): Supporting Maximum Occupant Load Per Floor
Exit routes must support the maximum permitted occupant load for each floor served. This isn't optional; it's engineered into the standard to prevent overcrowding during emergencies like well blowouts or chemical releases.
In oil and gas, calculate occupant load using building codes like IBC Table 1004.5—think 5 net sq ft per person for control rooms, up to 100 gross sq ft for production areas. I've audited rigs where operators crammed 50 workers into a 1,000 sq ft module, exceeding capacity by 20%. The fix? Recalibrate based on shift schedules and tasks, not wishful thinking.
- Stairways: 0.3 inches per occupant for upward travel; 0.2 inches downward.
- Doorways: 0.2 inches per occupant.
- Corridors: 0.15 inches per occupant if over 44 inches wide.
These units of width ensure clear passage. For a 20-person floor, you need at least 4 inches of stairway width—roughly 44 inches total, assuming handrails eat 4 inches each side.
1910.36(f)(2): No Capacity Decrease Toward Exit Discharge
The capacity of an exit route may not decrease in the direction of exit route travel to the exit discharge. Picture a funnel effect: wide upper decks narrowing to a single hatch on a platform. That's a violation waiting to trap workers.
Oil and gas sites often violate this with temporary setups—scaffolding chokepoints or valve manifolds blocking paths. On a Gulf of Mexico platform I consulted for, the main egress stair narrowed from 72 inches to 36 inches mid-descent due to pipe racks. We rerouted utilities, restoring flow and passing OSHA inspection.
Compliance demands uniform or increasing capacity downstream. Factors like riser height (max 9.5 inches for stairs) and tread depth (11 inches min) compound issues if widths shrink.
Oil and Gas Specifics: High-Hazard Egress Challenges
These facilities pack hazards—H2S zones, explosive atmospheres—amplifying egress needs. OSHA ties into 29 CFR 1910.1000 for air contaminants, but 1910.36(f) stands alone for capacity. Offshore, SEMS II (30 CFR 250.1915) echoes this, requiring muster stations with verified capacities.
Common pitfalls:
- Overestimating loads from contractor peaks without averaging.
- Ignoring "remote" areas like tank farms, where loads are low but distances long.
- Deferred maintenance shrinking paths via equipment creep.
Pro tip: Model with software like Pathfinder or hand-calculate per Appendix E to 1910.36. Test via drills; time 99% evacuation against RSET (Required Safe Egress Time) benchmarks from SFPE Handbook.
Actionable Steps for Compliance
Start with a floor-by-floor audit: map loads, measure widths, simulate flows. Reference OSHA's eTool for Means of Egress and IBC for loads. We've seen fines drop 80% post-audit in refineries—individual results vary by site specifics.
Transparency note: While 1910.36(f) is clear-cut, local AHJs or API RP 75 may layer nuances. Consult pros for hybrids like floating production units. Stay ahead; capacity isn't just code—it's crew survival.
