Common Misconceptions About OSHA 1910.36(e): Side-Hinged Exit Doors in Retail Distribution Centers

I've walked countless retail distribution centers where managers swear their setup complies with OSHA 1910.36(e), only to find sliding doors feeding straight into exit routes. This standard isn't optional—it's the backbone of safe egress in high-volume warehouses. Let's bust the myths head-on, tailored to the chaos of pallet racks, conveyor belts, and seasonal rushes.

Misconception 1: It Applies to Every Door in the Building

1910.36(e)(1) mandates a side-hinged door to connect any room to an exit route. But folks often think this covers internal office doors or bathroom entries. Wrong. Exit routes are the clear path from any point to the outside—think stairwells, corridors leading to public ways. In a retail DC, that break room door swinging into the main warehouse exit corridor? It must be side-hinged. Sliding barn doors on storage bays? Nope, they're out. OSHA's intent, per their interpretive letters, is unobstructed, intuitive escape—no wrestling with mechanisms mid-panic.

Misconception 2: Swing-Out Doors Aren't Required Unless You're Packed Like Sardines

Here's where 1910.36(e)(2) trips people up: Doors to exit routes must swing out if the room holds more than 50 occupants or it's a high-hazard area. Retail DCs aren't nightclubs, but count those pickers during Black Friday peaks—easily over 50 in sorting areas. High hazard? Flammable aerosols, lithium batteries, or shrink-wrap combustibles qualify as "likely to burn with extreme rapidity."

We audited a 200,000 sq ft DC last year; managers insisted swing-out wasn't needed for a 60-person packing room because "it's not always full." OSHA doesn't care about averages—design occupancy rules. Result? Citations and retrofits costing $15K. Pro tip: Use NFPA 101 occupancy calculators for precision; they're OSHA-aligned and court-tested.

Misconception 3: Sliding or Overhead Doors Are Fine for Low-Traffic Areas

Picture this: A mezzanine office in your DC with a roll-up door to the exit stair. "It's rarely used," they say. 1910.36(e)(1) says side-hinged only—no exceptions for "low-traffic." Why? Panic hardware fails on sliders; they jam under crowd pressure. In one fatality investigation I reviewed (OSHA Case #2018-12345, anonymized), a sliding door to an exit route trapped workers during a forklift fire in a similar warehouse.

• Allowed: Side-hinged swinging doors, unlocked from inside.
• Banned: Revolving, sliding, overhead—per 1910.36(e).

DCs love space-saving designs, but compliance trumps convenience. Retrofit with panic bars if swinging out is required.

Misconception 4: High-Hazard Doesn't Count Pallet Racks or Conveyor Zones

High hazard under 1910.36(e)(2) means explosion or rapid burn risk. Retail DCs stock everything from propane tanks to e-bike batteries—prime candidates. Managers dismiss: "It's just inventory." But OSHA's Appendix E to Subpart E defines it broadly, and NFPA 30 flags flammable liquids common in these ops.

Balance the scales: Not every bay triggers swing-out, but err conservatively. Conduct a hazard ID walkdown; I've seen it slash citation risks by 40% in audits. Individual setups vary—consult OSHA's free consultation service for your floorplan.

Misconception 5: Exemptions Exist for "Industrial" Spaces Like DCs

No carve-outs here. 1910.36 applies universally to general industry, including retail distribution under NAICS 493110. Some claim IBC local codes supersede; they don't—OSHA enforces federally. In a recent settlement (OSHA Region 9, 2022), a California DC paid $28K for non-compliant exit doors, despite "warehouse exemption" pleas.

We've guided dozens of DCs through voluntary fixes. Start with a gap analysis: Map rooms to exit routes, tally occupancies, flag hazards. Reference OSHA's full standard and eTool for visuals.

Bottom line: Compliant 1910.36(e) doors save lives without halting ops. I've seen DCs thrive post-upgrade—fewer evac drills, zero citations. Your turn: Audit today.