OSHA 1910.36(d) Compliance: Why Public Utilities Still Face Exit Route Injuries

OSHA's 1910.36(d) sets a clear bar: exit route doors must unlock from the inside without keys, tools, or special knowledge. Panic bars that lock only from outside? Fine for discharge doors. No restrictive alarms or devices that could fail in a pinch. And inside locks? Reserved strictly for mental health, penal, or correctional spots with constant supervision and evacuation plans. Public utilities—from substations to water treatment plants—often nail this compliance. Yet injuries persist. Here's why, drawn from years auditing high-risk sites.

The Compliance Trap in Utility Environments

Compliance checks the box on door hardware. But public utilities operate in unforgiving settings: remote substations battered by coastal winds, flooded pump stations, or high-voltage enclosures where egress means navigating energized gear. I've walked sites where panic bars gleamed OSHA-perfect, yet workers slipped on ice-slick thresholds during evac drills. 1910.36(d) doesn't mandate weatherproofing or anti-slip treatments—those fall to broader hazard assessments under 1910.22 walking-working surfaces.

Consider this: a California utility I consulted had fully compliant exit doors. During a mock fire, employees bolted fine—but piled up behind a forklift left blocking the route. OSHA 1910.37 demands clear exit paths, but daily ops in sprawling yards let obstructions creep in. Compliance is static; utilities are dynamic.

Unique Utility Hazards Beyond Door Locks

• Perimeter vs. Internal Exits: Utilities secure outer gates with padlocks (permitted if not primary exits), but internal doors comply. Injuries spike when crews mistake secondary paths in smoke or blackout.
• Environmental Extremes: Foggy Bay Area mornings or Sierra snow make compliant doors hard to grip. Panic bars freeze; latches stick from grit. 1910.36(d)(2) bars failure-prone alarms, but doesn't address mechanical wear from salt air.
• High-Hazard Overlays: Under 1910.269 for electric power generation, egress must integrate with arc-flash risks. Doors unlock, but radiant heat warps frames, slowing escape.

OSHA data from 2022 shows utilities logging 15% of manufacturing egress incidents, despite high compliance rates. NIOSH FACE reports highlight cases: a Texas substation worker, door compliant, tripped on unraveled grounding cable en route to safety.

Real-World Fixes I've Implemented

We once retrofitted a SoCal water utility's exits. Compliant? Yes. Injury-free? Not until we added glow-in-dark signage, widened approaches per 1910.36(b), and scripted drills factoring tidal surges. Result: zero egress incidents over three years. Key? Layered defenses.

Start with audits beyond hardware: simulate failures quarterly. Train on 1910.36 holistically—routes, not just doors. Install battery-backed lighting (1910.37(b)(1)) and auto-closers that don't jam. For utilities, integrate with SCADA for remote unlocks during remote-station emergencies, balancing security under NFPA 70E.

Actionable Steps for Utilities

1. Map Routes Annually: Use laser scans for obstructions; enforce housekeeping via JHA tracking.
2. Upgrade Hardware: Opt for UL-listed panic devices rated for corrosive environments.
3. Drill with Realism: Incorporate PPE drag-outs and low-vis scenarios; track via incident software.
4. Leverage Exemptions Wisely: No broad utility carve-outs exist—stick to (d)(3) limits.

1910.36(d) compliance is your baseline, not bulletproof vest. In public utilities, where stakes mix isolation and infrastructure, proactive evolution prevents the preventable. Reference OSHA's full egress standard and NIOSH utility alerts for deeper dives. Individual sites vary—tailor to yours.