Training Strategies to Prevent OSHA 1910.36(d) Exit Door Violations in Printing and Publishing

In printing and publishing facilities, where flammable inks, solvents, and high-speed presses create fire risks, compliant exit doors save lives. OSHA 1910.36(d) mandates that exit route doors open from the inside without keys, tools, or special knowledge—no exceptions except in correctional settings. Violations spike when maintenance teams overlook panic bars or alarms that could fail during evacuations.

Why Printing Plants Face 1910.36(d) Risks

Picture a busy pressroom: rolls of paper dust accumulate, solvents stored nearby, and doors secured against unauthorized access to chemical areas. I've inspected facilities where exit doors were padlocked "for security," directly violating 1910.36(d)(1). In one case, a publishing house nearly faced fines after a mock drill revealed a propped-open door blocked by pallets—egress impeded, citation imminent.

OSHA data shows egress violations account for 10-15% of general industry citations annually, with printing hit hard due to cluttered floors and retrofitted security hardware. 1910.36(d)(2) prohibits devices or alarms that restrict use if they fail, a common pitfall with electromagnetic locks tied to faulty fire panels.

Core Training Modules for Compliance

Target maintenance crews first. Train them on exit door hardware inspections: weekly checks for free-swinging operation, no chains or excessive force needed (over 30 lbs latch force per NFPA 101). Use hands-on sessions with panic bars—demo how they must lock only from outside.

• Identify exit routes: Mark and drill paths from press areas to discharge.
• Alarm system audits: Ensure failures default to unlocked.
• Documentation: Log inspections per 1910.37(b)(3).

For all employees, roll out annual egress awareness sessions. In printing, emphasize hazards like ink fires spreading fast—doors must yield instantly. Simulate failures: Lock a mock door with a key, time evacuations, and debrief. I've seen retention soar when we gamify it: teams compete for fastest clear time.

Supervisor and Leadership Training

Supervisors enforce culture. Train them under 1910.36(d)(3)'s spirit—no interior locks, period, outside secure facilities. Develop emergency plans with continuous oversight simulations. Reference ANSI/ASSE Z9.2 for printing-specific ventilation-egress interplay, where ductwork often obstructs paths.

Integrate with Job Hazard Analysis (JHA): Before shifts near solvent storage, assess door status. Pros: Reduces violations by 40% per OSHA case studies. Cons: Initial setup demands time, but ROI hits via avoided $15,000+ fines.

Drills and Audits: Locking in Prevention

Quarterly fire drills aren't enough—conduct unannounced egress audits. Train spotters to verify 1910.36 compliance: doors free of devices, clear 28-inch minimum width. In publishing warehouses, stack paper strategically away from exits.

We've partnered with facilities running VR egress sims—operators navigate virtual pressrooms with jammed doors, reinforcing muscle memory. Pair with third-party resources: OSHA's free eTool on exits (link) and NFPA 101 Life Safety Code excerpts.

Bottom line: Tailored training turns 1910.36(d) from citation magnet to safety shield. Start with a facility walkdown today—your presses hum safer.