When OSHA's 1910.36 Doesn't Apply in Transportation and Trucking
OSHA's 1910.36 standard sets the bar high for exit route design and construction, ensuring workers can evacuate safely in emergencies. But what about the transportation and trucking industries? Here, the rules can get a bit fuzzy.
Where 1910.36 Falls Short
While 1910.36 is a powerhouse in most workplaces, it's not the main event in transportation and trucking. Why? Because these industries often operate in unique environments like trucks, loading docks, and warehouses, where traditional exit routes might not cut it.
Take a truck, for example. The cab's design, while comfortable for long hauls, doesn't always align with 1910.36's exit route requirements. Sure, drivers need a way out, but the nature of the job means they're often on the move, making traditional exit routes impractical.
Alternative Standards and Practices
So, what fills the gap? Other OSHA standards and industry-specific practices come into play. For instance, 1910.178, which covers powered industrial trucks, addresses safety for forklift operators, including emergency exits. Similarly, 1910.23, which deals with walking-working surfaces, helps ensure safe access and egress in warehouses.
In my experience, working with transportation companies, we often find that customizing safety protocols to fit the specific needs of the job is crucial. This might mean training drivers on emergency procedures unique to their vehicles or designing loading docks with safety in mind from the ground up.
Real-World Application
Let's dive into a real-world scenario. I once consulted with a trucking firm where drivers were unsure about evacuation procedures during an emergency stop on a highway. We developed a tailored safety plan that included clear signage within the truck's cab and regular training sessions on emergency exits. This approach, while not directly aligned with 1910.36, ensured compliance with broader safety goals.
It's also worth noting that while 1910.36 might not apply, the overarching goal of OSHA is to protect workers. Therefore, companies in transportation and trucking must still adhere to the general duty clause, which requires employers to provide a workplace free from recognized hazards that could cause death or serious harm.
Resources and Further Reading
For those looking to delve deeper, the following resources can provide additional insights:
- OSHA Standard 1910.178 - Powered Industrial Trucks
- OSHA Standard 1910.23 - Walking-Working Surfaces
- OSHA Evacuation Plans and Procedures eTool
Based on available research, individual results may vary, but the key takeaway is clear: while 1910.36 might not be the go-to standard, safety in transportation and trucking remains non-negotiable. By understanding and applying the right mix of regulations and practices, companies can ensure their workers are protected, no matter where the road takes them.


