OSHA 1910.36(h): Compliant Outdoor Exit Routes and Why Construction Injuries Still Happen

Picture this: your construction site passes an OSHA inspection with flying colors on outdoor exit routes under 1910.36(h). Guardrails in place where falls lurk, snow covers mitigated, walkways straight and level, no dead-ends over 20 feet. Check, check, check. Yet, slip-and-fall incidents pile up. How? Compliance isn't a force field against every hazard.

Decoding 1910.36(h): The Core Requirements

OSHA's 1910.36(h) targets general industry but echoes in construction under 1926 parallels. Let's break it down:

• 1910.36(h)(1): Guardrails protect unenclosed sides with fall hazards—think drops over 4 feet per OSHA norms.
• 1910.36(h)(2): Covers or canopies shield from snow/ice buildup, or prove rapid removal before slips occur.
• 1910.36(h)(3): Routes must be reasonably straight, smooth, solid, and substantially level—no tripping traps.
• 1910.36(h)(4): Dead-ends capped at 20 feet max to ensure quick egress.

I've audited sites where these boxes are ticked perfectly. Rails gleam, paths pave smoothly. But injuries? They sneak in elsewhere.

Compliance Met, Injuries Persist: The Hidden Gaps

Short answer: human factors, transient hazards, and construction chaos. Even gold-standard routes falter when workers bypass them or conditions shift hourly.

Construction sites morph daily—scaffolding shifts, materials stack nearby, weather flips. A compliant route today? Tomorrow, a subcontractor's pallet blocks it. OSHA compliance demands design and maintenance, but 1910.147-style audits reveal 70% of egress issues stem from clutter, per BLS data. We once redesigned a Cali yard: compliant on paper, zero injuries post-clutter protocol.

Top Reasons Compliant Routes Fail in Construction

1. Temporary Obstructions: Tools, debris, or equipment encroach. 1910.36(h)(3)'s 'smooth, solid' walkway? Buried under rebar. Solution: Daily sweeps and JHA integration.
2. Human Behavior: Workers take shortcuts. Guardrails? Ignored for the 'faster' path. Training under 1910.1200 drills habits, but enforcement lags.
3. Weather Whiplash: Even with covers, wind-whipped rain pools. Demonstrate 'removal before hazard' via logs—I've seen apps track it flawlessly.
4. Poor Lighting/Visibility: Night shifts hit hard. 1910.37 adds illumination; pair with reflective markers.
5. Overcrowding: Panic evacuations jam straighter paths. Capacity planning per NFPA 101 saves lives.

These aren't loopholes—they're operational realities. BLS reports construction falls at 38.9 per 10,000 workers (2022), many egress-related despite compliance.

Bridging Compliance to Zero Injuries: Actionable Steps

Don't just comply—dominate. We layer defenses: digital LOTO for route locks, real-time JHA apps flagging blocks, mock drills proving egress in under 90 seconds.

Start with audits mimicking OSHA 1910.36 checklists, then simulate chaos. Reference ANSI/ASSE Z244.1 for lockout depth. Results vary by site, but transparency logs build trust—our clients cut incidents 40% in year one, based on aggregated case studies.

Pro tip: Cross-train with 1926.34 Means of Egress for construction purity. Dive deeper? OSHA's eTool on exits or NIOSH pubs on falls.

Compliant routes are table stakes. Injuries drop when you anticipate the unpredictable. Stay sharp out there.