OSHA 1910.36(b)(1) Compliance Checklist: Securing Two Exit Routes in Agricultural Workplaces

In agriculture, where massive barns, sprawling greenhouses, and processing sheds house everything from harvesters to harvest crews, a single blocked exit can turn an emergency into a nightmare. OSHA's 1910.36(b)(1) mandates at least two exit routes—positioned as far apart as practical—to ensure prompt evacuation if one path succumbs to fire, smoke, or structural failure. Exceptions exist under (b)(3) for workplaces with fewer than 10 occupants, but most ag operations exceed that threshold.

Why Two Exit Routes Matter in Ag: Real-World Stakes

Picture a grain silo fire in California's Central Valley. I've consulted on sites where hay bales or equipment choked the sole exit, trapping workers amid billowing smoke. Two well-spaced routes aren't optional; they're lifesavers. Compliance slashes evacuation times by up to 50%, per NFPA data, and dodges OSHA fines averaging $15,000 per violation.

Step-by-Step Checklist for 1910.36(b)(1) Compliance

Use this actionable checklist to audit and upgrade your ag facilities. Tick off each item, document findings, and recheck quarterly—ag environments shift with seasons and harvests.

1. Conduct a Facility-Wide Exit Route Inventory. Map every building: barns, packing houses, equipment sheds. Identify all current exits. Verify at least two per occupied space. In ag, count seasonal worker quarters and silos as "workplaces." Pro tip: Drones excel for overhead mapping in vast orchards.
2. Measure Separation Distance. Exit routes must be "as far away as practical"—ideally one-third the building's length apart, per OSHA interpretations. In a 300-foot barn, aim for 100 feet minimum separation. Use laser measurers; I've retrofitted dairies where routes were just 20 feet apart, begging for disaster.
3. Ensure Unobstructed Paths. Paths must remain free of storage, machinery, or livestock. Agriculture twist: Secure hay stacks, irrigation hoses, and tractors away from routes. Width? Minimum 28 inches for straight runs, 44 inches if turning (1910.37). No dead ends over 20 feet.
4. Assess Travel Distance Limits. Max 200 feet to an exit in sprinklered buildings; 150 feet unsprinklered (1910.36(b)(2)). Ag exception: Increase to 250/200 feet if approved flame-retardant construction. Test with stopwatches—employees should reach safety in under 2 minutes.
5. Upgrade Exit Hardware. Doors swing outward, unlatch with one motion—no padlocks or chains during occupancy. Panic bars mandatory for 50+ occupants. In humid greenhouses, opt for corrosion-resistant models.
6. Illuminate and Signage Check. Exits lit to 1 foot-candle minimum; signs visible from 100 feet. Ag-specific: Dust-proof LED fixtures for silo interiors; glow-in-dark for power outages in remote fields.
7. Incorporate Agriculture Hazards. Evaluate unique risks: Ammonia leaks in coops, pesticide spills in sheds. Routes must bypass fuel storage and volatile silos. Reference ANSI/ASB Z88.2 for chem-handling paths.
8. Train and Drill Employees. Annual fire drills simulating blocked routes. Document per 1910.36(e). Involve H-2A visa workers—they're often overlooked but vital to compliance.
9. Maintenance and Inspection Protocol. Weekly visual checks; monthly full audits. Log everything. Integrate with your JHA process for ongoing tweaks.
10. Seek Exceptions if Applicable. Under (b)(3), single exits OK for <10 occupants in small buildings. Submit OSHA variance request for unique ag setups, like remote pump houses.

Agriculture-Specific Pitfalls and Fixes

Farms aren't factories—plastic greenhouse films melt fast, blocking vision. Retrofit with fire-rated panels. In open-plan barns, temporary partitions for calving seasons can inadvertently halve route separation; plan modular layouts. We've helped Central Coast vineyards comply by widening loft access in 100-year-old structures, blending heritage with hazard controls.

Compliance isn't static. Seasonal influxes demand dynamic audits. Cross-reference with NFPA 101 for ag annexes, and consult OSHA's field ops manual for interpretations. Results vary by site, but this checklist has zeroed violations in dozens of operations I've audited.

Downloadable version? Pair this with Pro Shield's LOTO and JHA tools for seamless tracking. Stay safe out there—your crew depends on it.