October 17, 2025

Ensuring Compliance with OSHA 1910.36(a) in Hotel Exit Routes: A Comprehensive Checklist

Ensuring that your hotel's exit routes comply with OSHA's 1910.36(a) standards is crucial for the safety of your guests and staff. This checklist will guide you through the essential requirements to meet these regulations, ensuring your exit routes are safe, effective, and compliant.

Permanent Exit Routes

Every exit route in your hotel must be a permanent part of the building's structure. This means no temporary solutions or makeshift exits are allowed. I've seen hotels where management tried to cut corners by using temporary exits during renovations, only to face hefty fines during inspections. Ensure all your exit routes are built to last and are clearly marked as permanent fixtures.

Fire-Resistant Separation

Exit routes must be separated from other parts of the workplace by fire-resistant materials. If your hotel connects three or fewer stories, the materials must have a one-hour fire resistance-rating. For hotels with four or more stories, a two-hour fire resistance-rating is required. In my experience, upgrading to these standards often involves a significant renovation, but it's essential for compliance and safety. Regularly inspect these materials to ensure they meet the required ratings.

Limited Openings in Exits

Exits should only have openings necessary for access from occupied areas or to the exit discharge. Any opening into an exit must be protected by a self-closing fire door. These doors must remain closed or automatically close in an emergency when a fire alarm or employee alarm system is triggered. Based on available research, individual results may vary, but ensuring these doors are in good working order can significantly reduce the risk of fire spreading. Each fire door, including its frame and hardware, must be listed or approved by a nationally recognized testing laboratory, as defined in OSHA's Section 1910.155(c)(3)(iv)(A) and Section 1910.7.

Checklist for OSHA 1910.36(a) Compliance in Hotels

  • Verify that all exit routes are permanent parts of the hotel structure.
  • Ensure exit routes are separated by fire-resistant materials with the appropriate fire resistance-rating based on the number of stories.
  • Check that exits only have openings necessary for access, and all openings are protected by self-closing fire doors.
  • Confirm that all fire doors, including frames and hardware, are listed or approved by a nationally recognized testing laboratory.
  • Regularly inspect and maintain all exit route components to ensure they meet OSHA standards.

By following this checklist, you can ensure your hotel remains compliant with OSHA 1910.36(a) regulations. Remember, compliance not only helps avoid fines and legal issues but also ensures the safety and well-being of everyone in your hotel. For more detailed guidance, refer to the OSHA 1910.36(a) regulations directly or consult with a safety expert.

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