Ensuring Safe Exits in Wineries: Understanding OSHA 1910.36(d) Violations

In the dynamic environment of a winery, ensuring the safety of every employee is paramount. One critical aspect of workplace safety is adherence to OSHA's 1910.36(d) regulations regarding exit doors. These regulations are designed to guarantee that workers can evacuate quickly and safely during emergencies.

Common Violations in Wineries

From my experience consulting with wineries across California, the most common violations of 1910.36(d) include:

• Locked Exit Doors: It's not uncommon for winery managers to lock exit doors from the inside during operational hours, mistakenly thinking it will prevent theft or unauthorized access. However, according to 1910.36(d)(1), employees must be able to open an exit route door from the inside at all times without keys, tools, or special knowledge.
• Devices Restricting Emergency Use: Some wineries install alarms or devices on exit doors that could fail and restrict emergency egress, contravening 1910.36(d)(2). While the intent might be to monitor movement, these systems can pose a significant safety risk if they malfunction.
• Improper Locking in Special Facilities: Although 1910.36(d)(3) allows for locking exit doors from the inside in certain facilities like mental or correctional institutions, this does not apply to wineries. Any locking mechanism on exit doors in wineries is a direct violation.

These violations often stem from a lack of understanding or oversight, rather than intentional non-compliance. It's essential for winery management to stay informed and proactive in ensuring that their facilities meet these safety standards.

Practical Steps to Ensure Compliance

To maintain a safe working environment and comply with OSHA's regulations, wineries can take the following steps:

• Regularly inspect all exit doors to ensure they are unlocked and free from any devices that could hinder emergency egress.
• Conduct training sessions for all staff on the importance of keeping exit routes clear and accessible.
• Implement a safety audit program to identify and rectify any potential violations promptly.
• Consider using OSHA's resources and guides, such as the OSHA 1910.36 standard, to stay updated on compliance requirements.

By taking these proactive measures, wineries can not only avoid penalties but also foster a culture of safety that protects their workforce.

Based on available research, individual results may vary, but adherence to these guidelines can significantly enhance the safety and compliance posture of any winery. For further guidance, consider reaching out to safety consultants who specialize in the unique challenges of the wine industry.