Most Common OSHA 1910.36(h) Violations in Hotels: Outdoor Exit Route Pitfalls

Hotels thrive on seamless guest experiences, but outdoor exit routes—from poolside paths to parking lot walkways—often become OSHA citation hotspots. Under 29 CFR 1910.36(h), these routes must meet strict criteria to ensure safe evacuation. In my years auditing hospitality properties across California and beyond, I've seen the same four violations recur: missing guardrails, uncovered slippery paths, uneven walkways, and excessive dead-ends. Let's break them down with real-world hotel examples and fix-it strategies.

1910.36(h)(1): No Guardrails on Unenclosed Sides with Fall Hazards

This is the top offender in hotels, cited in over 25% of egress violations per recent OSHA data from NAICS 7211 (traveler accommodation). Picture a resort boardwalk elevated 6 feet above landscaping—without 42-inch guardrails, a panicked guest could tumble during an emergency.

We once consulted a coastal hotel where uneven terrain left open-sided paths unguarded. Inspectors slapped them with a serious citation after spotting a 4-foot drop-off. Fix it: Install OSHA-compliant guardrails (42 inches high, with toeboards if needed) wherever a fall exceeds 4 feet. Regular audits catch these before fines hit $16,131 per violation (2024 rates).

1910.36(h)(2): Uncovered Routes in Snow/Ice-Prone Areas

In northern or mountainous hotels, uncovered outdoor exits invite ice buildup, turning evacuation paths into slip zones. OSHA requires coverage or a documented removal plan if snow is likely—yet many properties skip both, assuming "mild winters."

A Midwest chain learned the hard way: after a citation for icy, untreated walkways leading to guest rooms, they faced $14,502 plus rework costs. Based on OSHA's Severe Violator Enforcement Program cases, proactive snow protocols (e.g., salted paths monitored hourly) satisfy the "demonstration" clause. Pro tip: Log maintenance in digital tools for inspector proof.

• Install awnings or canopies over critical routes.
• Develop weather-specific SOPs with timed salting schedules.
• Train staff quarterly on 1910.147 lockout for canopy maintenance.

1910.36(h)(3): Crooked, Rough, or Uneven Walkways

Hotel landscapes evolve—cracked concrete from pool expansions or tree roots creates tripping hazards. The rule demands "reasonably straight, smooth, solid, substantially level" surfaces. Violations spike in older properties where deferred maintenance meets guest traffic.

I've walked routes at a Vegas Strip hotel that zigzagged 15 degrees off-straight over 50 feet, uneven pavers shifting underfoot. OSHA flagged it immediately. Compliance means slopes under 1:20, no gaps wider than 1/2 inch, and slip-resistant materials (coefficient of friction ≥0.5 per ANSI A1264.2). Repave proactively; it's cheaper than citations.

1910.36(h)(4): Dead-Ends Exceeding 20 Feet

Service alleys or garden paths doubling as exits often dead-end beyond 6.2 meters, trapping evacuees. Hotels cite "space constraints," but OSHA doesn't buy it—alternate routes or shorten paths are mandatory.

One urban hotel's 35-foot blind alley to parking got cited during a fire drill inspection. Solution: Reroute or add signage directing to compliant exits. Reference NFPA 101 for design synergies; it aligns with OSHA on dead-end limits.

These violations aren't just paperwork—they risk lives in seconds. We recommend annual mock drills mapping all outdoor routes against 1910.36(h). Cross-check with local AHJ for hotel-specific tweaks. For deeper dives, OSHA's eTool on Exit Routes offers free visuals, and their citation database (via QuickTakes) reveals hotel trends. Stay ahead: audit now, evacuate safely later.