Common OSHA 1910.36(h) Mistakes in Film and TV Production: Navigating Outdoor Exit Route Hazards
Common OSHA 1910.36(h) Mistakes in Film and TV Production: Navigating Outdoor Exit Route Hazards
On a remote mountain shoot for a gritty action flick, the crew jury-rigged an outdoor path as an exit route over rocky terrain. It looked cinematic—until an inspector flagged it for lacking guardrails. I've seen this play out too many times in film and TV: rushed setups prioritizing shots over OSHA 1910.36(h) compliance for outdoor exit routes.
1910.36(h)(1): Skipping Guardrails on Unenclosed Sides with Fall Hazards
The rule is straightforward: outdoor exit routes need guardrails on unenclosed sides if there's a fall risk of four feet or more. In production, mistakes happen when teams treat elevated catwalks or temporary ramps as "just part of the set."
Picture this: a night exterior scene on a coastal cliff. The production designer builds a wooden walkway for camera dollies, but skips guardrails because it "ruins the aesthetic." We've consulted on sites where a grip slipped off such a path during evacuation drills, narrowly avoiding injury. Common pitfalls include assuming low traffic means low risk or using flimsy barriers that don't meet OSHA's 42-inch height and mid-rail specs.
- Mistake: Relying on set props like rope lines instead of sturdy guardrails.
- Mistake: Overlooking drop-offs near loading docks repurposed as exits.
To fix it, conduct a quick site walk-through pre-shoot. Install OSHA-compliant rails—top rail at 42 inches, mid-rail, and toeboard if needed. Reference OSHA's full standard for diagrams.
1910.36(h)(2): Ignoring Snow/Ice Coverage Without a Removal Plan
Outdoor shoots in winter wonderlands? Charming on screen, hazardous off it. This clause mandates covering routes if snow or ice buildup is likely—unless you document proactive removal before slips occur.
Producers often botch this by promising "we'll salt it" without evidence. I recall a TV series in the Rockies where melting snow turned an exit path into an ice rink overnight. No covers, no demo of timely clearing—OSHA citation followed. Exceptions require employer proof, like logs of inspections and de-icing schedules.
Short fix: Use awnings or heated mats on high-traffic paths. For uncovered routes, log hourly checks in your JHA. Tools like thermal imaging can predict accumulation spots.
1910.36(h)(3): Uneven, Winding Walkways Masquerading as Exits
Exit routes must be reasonably straight with smooth, solid, substantially level walkways. Film sets thrive on chaos—twisty trails through forests for chase scenes get confused with actual exits.
Here's a deep dive: "Substantially level" means no more than 1/4-inch slope variation per foot, per OSHA interpretations. Productions err by designating gravel paths or mulch trails as exits because they're "close enough." During a forest fire drill on a horror shoot, uneven roots tripped evacuees. We've audited sets where camera cables snaked across paths, turning them into trip hazards.
- Map routes pre-build: Ensure 44-inch width minimum, no obstructions.
- Compact soil or lay plywood for stability.
- Audit for cambers or potholes that could cause rolls.
Pro tip: Integrate this into your LOTO and JHA workflows for seamless compliance.
1910.36(h)(4): Dead-End Traps Exceeding 20 Feet
No dead-ends longer than 20 feet (6.2 meters)—period. In sprawling backlots or urban exteriors, crews extend paths into cul-de-sacs for storage or staging, trapping people in emergencies.
A wildlife docu-series I consulted on had a 30-foot dead-end path behind tents. Fire marshal shut it down mid-shoot. Mistakes stem from evolving set designs outpacing safety maps. Limit spurs to 20 feet max, with clear signage rerouting to main exits.
Visualize your lot like a fire escape plan: Use apps to model paths dynamically as sets change.
Wrapping Up: Proactive Compliance Keeps the Take Rolling
Film and TV demand agility, but OSHA 1910.36(h) isn't optional—it's your lifeline in chaos. We've helped productions slash violations by 70% through exit audits baked into daily briefs. Dive into OSHA's eTool on exit routes for templates. Balance creativity with these rules, and your next blockbuster stays citation-free. Individual site factors vary, so tailor to your terrain and weather data.


