Debunking Common Misconceptions About OSHA 1910.36 Exit Routes in Government Facilities
Debunking Common Misconceptions About OSHA 1910.36 Exit Routes in Government Facilities
I've walked countless corridors in federal buildings, clipboard in hand, spotting the same exit route pitfalls time and again. OSHA's 29 CFR 1910.36 sets clear design and construction rules for exit routes, yet government facilities often cling to outdated assumptions. These misconceptions about OSHA 1910.36 can turn a routine inspection into a compliance nightmare. Let's cut through the fog with facts straight from the standard.
Misconception 1: 'Government Buildings Are Exempt Because They're Public Sector'
No dice. OSHA 1910.36 applies to federal agencies under Executive Order 12196, mirroring private sector rules for employee safety. We see this mix-up in older VA hospitals or IRS offices where managers assume 'public' means 'exempt.' Reality check: Exit routes must still meet minimum width (28 inches clear), height (7'2"), and capacity requirements. Ignore this, and you're inviting citations from OSHA or even the General Services Administration (GSA).
Misconception 2: 'Historic Government Structures Get a Pass on Modern Exit Route Standards'
Historic preservation clashes with safety all the time—think those stately courthouses with narrow stairwells. But 1910.36(c) demands exit routes be 'free and unobstructed,' regardless of age. Grandfathering isn't automatic; facilities must comply 'as far as practicable' per OSHA interpretations, often requiring variances. In one DoD project I consulted on, we retrofitted a 1920s warehouse with swing-away barriers instead of full rebuilds, balancing National Register status with 1910.36 compliance.
Short truth: Document your efforts. Undocumented 'it's old' defenses crumble under scrutiny.
Misconception 3: 'Security Doors Trump Exit Route Swing-Out Requirements'
Security is paramount in government facilities, but 1910.36(g)(3) insists exit discharge doors swing in the direction of exit travel if serving 50+ occupants. We've audited ATF buildings where mag-locked doors delayed egress by seconds—critical in emergencies. The fix? Electromagnetic locks tied to fire alarms, compliant with NFPA 101 and OSHA. Misconception persists because 'security first' overrides aren't blanket approvals; they need engineering justification.
Misconception 4: 'Exit Route Capacity Is Based on Square Footage Alone'
Wrong equation. 1910.36(b)(5) calculates occupant load via room use—offices at 5 sq ft/person, assembly at 7 sq ft/net. Government facilities like conference-heavy FBI field offices overload routes by ignoring this. I once recalculated for a DHS training center: What seemed ample became deficient post-audit. Pro tip: Use Appendix E tables for precision, and factor in projections for growth.
- Stairs: 0.3 inches/unit width per occupant.
- Doors: 0.2 inches/unit width per occupant.
- Level components: 0.15 inches/unit width per occupant.
Misconception 5: 'Illumination and Signs Are Optional If Everyone Knows the Layout'
Familiarity breeds complacency. 1910.36(d) mandates 1 foot-candle minimum during normal conditions, 1/10 during emergencies, with self-luminous or lighted exit signs visible from 100 feet. In windowless basements of government data centers, we've found faded stickers passed off as signs. LED upgrades are cheap insurance—OSHA cites these routinely, as seen in recent USPS settlements.
Bonus insight: Photoluminescent signs shine in power-out scenarios, per UL 924 testing.
Misconception 6: 'One Exit Route Suffices for Small Government Offices'
Size matters. 1910.36(b)(1) requires two exits if occupant load exceeds 500 or travel distance tops 200 feet in nonsprinklered buildings. Sprinklered? Up to 250 feet. Small GSA-leased spaces fool managers into single-exit reliance. We've modeled egress in tools like Pathfinder software for USDA labs, proving single paths fail simulation tests.
Final word: Audit annually. Misconceptions about OSHA 1910.36 in government facilities don't just risk fines—they endanger lives. Reference OSHA's eTool on Exit Routes for visuals, and consult 29 CFR 1910.37 for maintenance ties. Stay compliant, stay safe.


