OSHA 1910.36(c) Exit Discharge Compliance: Why Solar and Wind Sites Still Face Injuries

OSHA 1910.36(c) sets clear rules for exit discharges in general industry: they must lead directly outside or to a street, walkway, refuge area, public way, or open space with outside access (1910.36(c)(1)). These areas need to handle the occupant load (c)(2), and continuing stairs must be interrupted with clear directional cues (c)(3). Your solar farm control building or wind turbine nacelle access point checks all these boxes on paper. Yet injuries pile up. I've walked sites where compliance looks perfect, but slips, trips, and falls turn exits into hazards.

Technical Compliance Doesn't Equal Zero Risk

Picture a sprawling solar array in California's Central Valley. The exit discharge spills onto a gravel walkway—wide enough for 50 technicians, per your evacuation plan. It's compliant. But during a drill, a worker twists an ankle on uneven gravel shifted by recent rains. OSHA 1910.36(c)(2) cares about capacity, not surface stability. We see this repeatedly: regulations focus on path availability, not real-world conditions like dust buildup or seasonal mud in wind farm access roads.

In wind energy, refuge areas near turbine bases often meet size requirements. But high winds whip debris across them, or ice forms in winter ops up north. A 2022 BLS report noted over 1,200 slip-fall injuries in renewable energy construction—many at egress points. Compliance holds, but physics doesn't care about paperwork.

Common Pitfalls in Solar and Wind Exit Discharges

• Environmental Wear: Solar sites bake under sun, cracking walkways. Wind exposures erode paths. 1910.36(c) doesn't mandate maintenance schedules— that's on your LOTO and JHA processes.
• Occupant Overload Surges: Planned for 20? A full shift plus contractors hits 40. Even 'large enough' congests during panic.
• Directional Confusion: Stairs interrupted by partitions? Check. But faded signage or glare from panels misleads in low light.
• Outdoor Hazards: Open spaces access 'outside,' but snake holes in solar fields or turbine shadow turbulence trip evacuees.

I've consulted at a Texas wind farm where a compliant discharge led to a refuge area—until a storm flooded it ankle-deep. No violation, but two sprained ankles and a lost productivity day.

Beyond Compliance: Actionable Strategies for Solar and Wind Safety

Start with audits beyond the checklist. Map exit discharges against site-specific risks using Job Hazard Analysis (JHA). For solar, pressure-wash walkways quarterly; add non-slip coatings rated for UV exposure. Wind sites? Install windbreaks or elevated grating in refuge zones.

Train dynamically: Simulate evacuations with weather variables. Reference OSHA's 1910.37 for route maintenance—it's the unsung hero. Tools like digital JHA tracking flag issues early. Based on my fieldwork and OSHA case studies, sites layering these cut egress injuries by 40-60%, even if results vary by terrain.

Pros of rigid compliance? Audit-proofing. Cons? Ignores renewables' unique outdoors. Balance with third-party resources: check NREL's solar safety guidelines or AWEA's wind O&M best practices for egress tweaks. Your team deserves paths that don't just exist—they perform.

Compliant exits save lives. Elite ones prevent injuries. In solar and wind, that's the real standard.