Uncorking the Truth: Debunking Misconceptions About 1910.36(c) Exit Discharges in Wineries

The wine industry, while steeped in tradition, must also navigate the complexities of modern safety regulations. One such regulation, 1910.36(c) from OSHA's standards on exit routes, often leads to misconceptions, especially in the unique environments of wineries. Let's dive into the common myths and clarify the facts to ensure your winery remains both compliant and safe.

Misconception 1: Exit Discharges Can Lead to Any Open Space

Some winery owners believe that as long as an exit leads to an open space, it meets the requirements of 1910.36(c). However, the regulation is more specific. 1910.36(c)(1) states that each exit discharge must lead directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside. In my experience working with wineries, it's crucial to ensure that these exit routes are not just open but also accessible and lead to a safe area.

Misconception 2: Size of the Exit Discharge Area Doesn't Matter

Another common misunderstanding is that the size of the exit discharge area is irrelevant. According to 1910.36(c)(2), the area must be large enough to accommodate the building occupants likely to use the exit route. This is particularly important in wineries, where events might increase the number of occupants. We've seen cases where wineries underestimated the required space, leading to non-compliance and potential safety hazards during evacuations.

Misconception 3: Exit Stairs Can Continue Without Interruption

It's a myth that exit stairs can continue indefinitely without clear indications of where the exit discharge is located. 1910.36(c)(3) mandates that exit stairs continuing beyond the level of the exit discharge must be interrupted at that level by doors, partitions, or other effective means to clearly indicate the direction of travel. In wineries, where multi-level structures are common, ensuring these indications are clear can be the difference between a safe evacuation and a chaotic one.

Ensuring Compliance and Safety in Wineries

To debunk these misconceptions and ensure your winery meets OSHA standards, consider the following steps:

• Conduct a thorough assessment of your current exit routes and discharge areas.
• Consult with safety experts who specialize in the unique challenges of the wine industry.
• Regularly update your safety protocols to reflect changes in occupancy or building modifications.

Based on available research and our experience, implementing these measures can significantly enhance safety while ensuring compliance. Individual results may vary, and it's important to consider the specific layout and operations of your winery.

For further reading, the OSHA website offers detailed guidance on exit routes and discharge requirements. Additionally, resources from the Wine Institute can provide industry-specific insights into safety management.