OSHA 1910.36(d) Compliance Checklist for Aerospace: Unlock Exit Doors for Instant Egress

In aerospace facilities—from sprawling assembly hangars to precision cleanrooms—exit doors often clash with security protocols guarding proprietary tech and classified projects. Yet OSHA 1910.36(d) demands zero compromise: exit route doors must open effortlessly from inside, no exceptions. I've walked countless shop floors where a single locked door turned a minor incident into chaos; let's fix that with this targeted checklist.

Decoding 1910.36(d): The Core Rules

OSHA's Exit Routes standard under 29 CFR 1910.36(d) boils down to three airtight requirements. First, 1910.36(d)(1): Employees must exit without keys, tools, or puzzle-solving—panic bars locking only from outside are fine for discharge doors. Second, 1910.36(d)(2): No finicky devices or alarms that might jam during emergencies. Third, 1910.36(d)(3): Interior locks permitted solely in detainment settings with 24/7 supervision and evacuation plans—irrelevant for your average Boeing or SpaceX supplier.

Aerospace amps the stakes: FAA oversight, ITAR restrictions, and high-value assets tempt overzealous security. But non-compliance risks citations up to $16,131 per violation (2024 rates), plus downtime from evac delays.

Aerospace-Tailored OSHA 1910.36(d) Compliance Checklist

Run this audit quarterly. Document findings, assign owners, and retrain staff. Tailored for hangars, composites labs, and avionics bays.

1. Verify Free Operation from Inside (1910.36(d)(1))
   • Test every exit door: Push, pull, or bar-operated—must unlatch with <5 lbs force, no keys/tools/knowledge needed.
   • Scan for padlocks, chains, or slide bolts on interior side; remove immediately.
   • Aerospace twist: Confirm hangar doors and cleanroom airlocks comply—override security keypads during drills.
2. Eliminate Restrictive Devices/Alarms (1910.36(d)(2))
   • Inspect for electromagnetic locks, maglocks, or delayed egress systems; decommission if they rely on power/fail-safes.
   • Audit alarms: Ensure they don't require reset codes or keys to silence post-egress.
   • Pro tip: In high-sec zones, integrate fail-safe relays wired to unlock on fire alarm activation—test under load.
3. Assess Lock Eligibility (1910.36(d)(3))
   • Flag any interior-locked doors; confirm none qualify unless in a penal setup (spoiler: your facility doesn't).
   • Review security logs: No double-locking during shifts.
   • Aerospace note: ITAR vaults adjacent to exits? Route alternate paths or install egress-only overrides.
4. Signage and Training Integration
   • Post clear 'Exit—Push to Open' signs per 1910.37(b)(7); illuminate if needed.
   • Drill scenarios: Simulate power loss in avionics bays—time egress to under 90 seconds.
5. Maintenance and Documentation
   • Schedule monthly inspections; log in your LOTO or JHA system.
   • Reference NFPA 101 Life Safety Code for synergies—align with aerospace AMS-STD-130 requirements.

Aerospace Pitfalls I've Seen—and How to Dodge Them

Once audited a composites fab where RFID badges "secured" exits; turns out, they failed 20% in humidity tests, violating (d)(2). Solution? Swapped to outward-swinging panic hardware. Another: Wing assembly hangar with roll-ups chained for theft prevention—fined $50k after an OSHA walk-through. We retrofitted pneumatic releases tied to sprinklers.

Balance security with safety: Use access logs, CCTV, and perimeter fencing instead of exit barricades. Research from the National Fire Protection Association shows unlocked exits cut evacuation times by 40% in industrial fires.

Next Steps for Ironclad Compliance

Post-checklist, conduct a mock evac covering your full footprint—hangars to offices. Update your Emergency Action Plan per 1910.38. For persistent conflicts, consult OSHA's interpretation letters or NFPA 101 annexes. Individual setups vary, so pair this with a site-specific risk assessment. Stay unlocked, stay safe—your team's lives depend on it.