Debunking Common Misconceptions About OSHA 1910.36(c) Exit Discharge in Agriculture

In agricultural operations—from sprawling packing sheds to towering grain elevators—OSHA 1910.36(c) sets clear rules for exit discharges. Yet, misconceptions persist, potentially leaving workers trapped during emergencies. I've audited dozens of farm facilities where these myths led to citations and close calls. Let's cut through the confusion on 1910.36(c)(1), (c)(2), and (c)(3).

Misconception 1: Any Door to the Outside Counts as a Valid Exit Discharge

1910.36(c)(1) requires each exit discharge to lead directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside. In agriculture, operators often assume a barn door dumping into a muddy equipment yard suffices. Wrong.

That yard might block escape if vehicles clog it or flooding hits. We once redesigned a California dairy's exit after an OSHA inspector flagged a door leading to a fenced manure lagoon—hardly a "public way." True compliance demands clear, direct paths to safety, not detours through hazards like crop fields or livestock pens.

Misconception 2: Size Doesn't Matter in Low-Occupancy Ag Buildings

Under 1910.36(c)(2), the street, walkway, refuge area, public way, or open space must accommodate the building occupants likely using that exit route. Ag pros shrug this off, claiming seasonal crews or small crews mean no big deal.

• Grain elevators: A narrow alley might handle 5 workers daily but fail for 50 during harvest.
• Greenhouses: Open fields seem spacious, but uneven terrain or irrigation ditches create bottlenecks.

Calculate based on maximum occupancy—OSHA's formula in 1910.36(b) uses occupant load factors like 3 net sq ft per person for assembly areas. In my experience consulting orchards, undersized discharges have caused evacuation pileups during fire drills. Always verify capacity; it's not optional.

Misconception 3: Continuous Stairs Are Fine If They Eventually Reach Outside

1910.36(c)(3) mandates interrupting exit stairs continuing beyond the discharge level with doors, partitions, or other means clearly indicating the exit discharge direction. Ag facilities with multi-level silos or processing towers ignore this, letting stairs snake uninterrupted to the roof or basement.

Picture a pesticide mixing room fire: Workers hesitate, unsure if stairs lead out or deeper in. Effective barriers—like a vision panel door or railing gap—guide them right. OSHA letters of interpretation confirm: ambiguity kills. We've retrofitted ladder-like stairwells in nut processing plants with simple partitions, slashing confusion risks.

Why Agriculture Gets It Wrong—and How to Fix It

Agriculture isn't exempt from 1910 Subpart E; 1928.21 incorporates general industry exit rules. Misconceptions stem from rural layouts where "outside" feels intuitive, but regs prioritize occupant flow. Start with a walkthrough: Map exits, measure discharge areas, test signage.

For deeper dives, check OSHA's eTool on Exit Routes or NFPA 101 alignments. Individual sites vary—sloped fields might need gravel walkways—but compliance boosts survival odds. Get it right; your crew depends on it.