Debunking Common Misconceptions About OSHA 1910.36(b)(3) Single Exit Route Requirements

OSHA 1910.36(b)(3) allows a single exit route in specific scenarios: when the number of employees, building size, occupancy, or workplace arrangement ensures all can evacuate safely in an emergency. I've walked countless shop floors in California's industrial hubs, spotting teams misapplying this rule during audits. Let's cut through the confusion with facts from the standard itself.

Misconception 1: Single Exits Are Never Allowed

The big one. Many EHS managers hear "two exits required" and slam the door on single-exit designs. But 1910.36(b)(3) explicitly permits them if conditions align for safe egress. Picture a small warehouse with five workers, under 10,000 square feet, no high-hazard ops—perfectly compliant. We see this myth trip up retrofits, forcing unnecessary expense.

OSHA's preamble to the final rule clarifies: it's about risk-based evaluation, not blanket bans. Dead-end corridors max out at 20 feet for single exits, per 1910.36(b)(1), but the single-route provision overrides in low-risk setups.

Misconception 2: Building Size Alone Dictates Compliance

"Over 75 feet travel distance? Two exits mandatory." Not quite. While 1910.37(b)(1) caps common path of travel at 75 feet, 1910.36(b)(3) weighs occupancy and employee count too. A sprawling single-story facility with dispersed, low-density staffing might qualify.

In one consultation for a SoCal parts fab, the client obsessed over square footage. We mapped evacuation times using NFPA 101 annexes—under 2.5 minutes for all. Single exit held up under scrutiny. Always model your space; don't default to size myths.

Misconception 3: It Only Applies to New Buildings

Existing structures get a pass? Nope. The standard covers all workplaces post-1989 adoption, with no grandfather clause for exits. Retroactive audits catch this—I've advised on upgrades where "it's always been this way" nearly triggered citations.

• Check common paths: Max 75 feet to exit discharge.
• Assess hazards: Flammables or crowds demand dual paths.
• Document rationale: Prove safe evacuation via drills or sims.

Misconception 4: Safe Evacuation Means 'Fast Enough for Everyone'

Evacuation isn't a sprint; it's risk-managed flow. Critics argue single exits doom mobility-impaired workers. Truth: 1910.36(g)(3) requires accessible routes, but single-exit allowance hinges on overall arrangement. Integrate areas of refuge or phased evac if needed.

Research from NIST fire models shows low-occupancy single exits perform well under smoke control. We balance this in audits: pros of cost savings versus cons of single-point failure. Train employees on the plan—drills reveal real gaps.

Misconception 5: OSHA Ignores It in Inspections

Think regulators overlook single exits? Citations spike here—over 500 in recent years per OSHA data. Focus on proof: employee rosters, floor plans, hazard analyses. I've prepped sites where solid docs turned potential violations into "no action."

Pro tip: Cross-reference with 1910.37 for maintenance and 1910.38 for plans. When in doubt, run a tabletop evac scenario.

Actionable Steps for Compliance

Assess your site today. Map paths, count heads per shift, simulate emergencies. Reference OSHA's eTool or NFPA 101 for depth. Individual results vary by layout—consult pros for tailored audits. Stay compliant, keep teams safe.