When OSHA's Exit Route Standards Fall Short in Film and TV Production

Film and television production environments are unique beasts. With their ever-shifting sets, temporary structures, and high-pressure schedules, these workplaces often stretch the limits of standard safety regulations like OSHA's 1910.36 on Design and Construction Requirements for Exit Routes.

So, when does this regulation not quite fit the bill in the world of film and TV? Let's dive in.

Temporary Sets and Structures

One of the biggest challenges in applying 1910.36 to film and TV production is the temporary nature of sets and structures. The standard assumes a more permanent workplace, which doesn't always align with the reality of shooting on location or in a studio.

For instance, a set might be built for a single scene and then dismantled. In these cases, ensuring that exit routes meet the full design and construction requirements of 1910.36 can be impractical or even impossible. We've seen situations where the need for quick set changes has led to compromises in exit route design, like narrower passages or less durable materials.

Highly Variable Work Environments

Another area where 1910.36 can fall short is in the highly variable nature of film and TV work environments. The standard is designed for more static workplaces, but in production, the layout can change from day to day or even hour to hour.

This variability makes it challenging to maintain consistent, compliant exit routes. I've been on sets where the crew had to navigate through a maze of equipment and props to reach an exit, which clearly doesn't meet the spirit of 1910.36, even if the route itself technically complies.

Specialized Equipment and Hazards

Film and TV productions often involve specialized equipment and unique hazards that aren't fully addressed by 1910.36. For example, the use of pyrotechnics, heavy lighting rigs, or complex rigging systems can create additional exit route challenges.

In these cases, the standard's focus on design and construction may not be enough. We need to consider how these specialized elements impact egress and emergency response. The presence of flammable materials or the need for quick evacuation in case of equipment failure often requires more tailored safety measures than what 1910.36 alone provides.

What Can Be Done?

Given these limitations, what can film and TV productions do to ensure safety while working within the constraints of 1910.36?

• Conduct Regular Safety Assessments: Regularly evaluate the set layout and exit routes, especially as the production evolves.
• Implement Temporary Measures: Use temporary signage, lighting, and barriers to guide crew members to safe exits, even if the routes themselves don't fully comply with 1910.36.
• Train Crew on Emergency Procedures: Ensure that everyone on set understands the emergency evacuation plan, including alternative exit routes if primary ones are blocked.
• Consult with Safety Experts: Work with safety consultants who have experience in film and TV production to develop customized safety plans that address the unique challenges of these environments.

By taking these steps, productions can enhance safety even when the standard exit route requirements don't perfectly apply. Remember, while 1910.36 provides a crucial framework, it's just one piece of the puzzle in ensuring a safe working environment on set.

For further reading on safety in film and television production, check out resources from the OSHA Movie and Television Production Safety page and the Safety on the Set initiative, which offer more specialized guidance for this industry.