Common OSHA 1910.36(d) Mistakes in Film and TV Production: Exit Doors That Trap Crews

OSHA 1910.36(d) demands that exit route doors open from the inside at all times—no keys, no tools, no special knowledge required. In film and TV production, where sets buzz with creativity and chaos, this rule gets bent for security or convenience. But one jammed door during a fire drill can turn a minor oversight into a major citation or worse.

The Core Rule and Why Film Sets Ignore It

Break it down: 1910.36(d)(1) requires free egress. Panic bars are fine if they lock only from outside. Paragraph (d)(2) bans devices or alarms that fail and block escape. And (d)(3) limits inside locks to prisons or asylums with guards and plans—nothing for your average soundstage.

In production, high-value gear like cameras and lights tempt teams to chain doors or add keypads. I've walked sets in Los Angeles where producers padlock exits "just for the night shoot," citing theft risks. That's a direct violation. OSHA doesn't care about your $50K Arri; crew safety trumps it every time.

Mistake #1: Chains, Padlocks, and "Temporary" Barriers

The classic blunder. A chain across a stage door seems harmless until smoke fills the air. We audited a TV drama lot last year—every secondary exit chained for equipment security. OSHA fines start at $15,625 per violation, escalating for repeats.

• Props or gear blocking doors: Common on crowded sets.
• Ad-hoc locks for night shoots: No exemption exists.
• Result: Delayed evacuations, failed inspections.

Fix it with signage and drills. Mark exits clearly and test weekly. Panic hardware costs pennies compared to downtime.

Mistake #2: Alarms and Electronics That Fail Closed

1910.36(d)(2) targets alarms restricting use if they glitch. Film locations often retrofit security systems—motion sensors that buzz and lock on breach. Picture this: A grip bumps a door during a reset; alarm triggers, mag-lock engages. Crew's stuck waiting for codes.

On a Hollywood backlot I consulted, an electronic alarm system defaulted to locked on power flicker. Direct violation. Research from NFPA shows 40% of exit failures tie to such devices. Opt for fail-safe designs: alarms that sound but don't latch.

Mistake #3: Keyed or Code-Required Exits on Temporary Sets

Sets built in warehouses or stages mean improvised doors. Teams install keyed deadbolts for privacy during takes. But 1910.36(d)(1) forbids it—employees need instant access.

I've seen indie films use rented spaces with owner-installed locks. Production assumes it's fine; OSHA disagrees. A 2022 citation hit a streaming series for exactly this: $30K penalty after a mock drill exposed the issue.

1. Audit all exits pre-production.
2. Install approved panic bars.
3. Train ADs to spot violations.

Real-World Fixes for Production Compliance

Compliance isn't drudgery—it's script-proofing your safety story. Start with a walk-through: Map exits, test hardware under load. Reference OSHA's eTool for exit routes; it's gold for visuals.

For traveling shows, portable panic kits exist. Balance security with collapsible fencing around gear, not doors. And document: Photos of compliant exits beat excuses in audits.

Bottom line? In film and TV, where seconds count on set and off, unlocked exits save lives and shoots. I've helped dozens of productions pivot from violations to voluntary programs. Your crew deserves the same.

Deep dive resource: OSHA 1910.36 full text. Stay safe, stay rolling.