Top OSHA 1910.36(e) Violations in Oil and Gas: Side-Hinged Exit Doors Done Right

I've walked countless oilfield sites where a simple door choice turns into an OSHA nightmare. OSHA 1910.36(e) mandates side-hinged doors for any room connecting to an exit route—straightforward on paper, but oil and gas operations love bending rules with high-hazard setups like flare pits, compressor stations, and control rooms packed with volatile hydrocarbons.

Breaking Down 1910.36(e): The Rule That Keeps Evacuations Smooth

Under 1910.36(e)(1), only side-hinged doors can link rooms to exit routes—no sliding, rolling, or barn doors allowed. Then 1910.36(e)(2) kicks in: those doors must swing outward if the room holds over 50 occupants or qualifies as high-hazard (think contents that burn fast or explode, per OSHA's definition).

In oil and gas, high-hazard areas abound: mud logging units, frac vans, and wellhead control rooms often exceed occupancy limits during shifts or house flammable gases. Violations here aren't just citations—they're evacuation blockers in emergencies.

Violation #1: Sliding and Overhead Doors Masquerading as Exits

The most cited offender? Non-side-hinged doors. Picture a rig workshop with a roll-up garage door labeled as the "exit." OSHA inspectors hammer this in oil and gas, citing it in 25% of egress violations per recent BLS data on petroleum extraction incidents.

• Why it happens: Convenience for equipment access in drilling ops or tank farms.
• Real-world hit: A Permian Basin site I audited had a sliding door on a 60-person briefing room—straight 1910.36(e)(1) violation, $15K fine.
• Fix: Retrofit with side-hinged swing doors, minimum 32-inch clear width.

Violation #2: Inward-Swinging Doors in High-Hazard Zones

Even with side-hinged doors, direction matters. Inward swingers in high-hazard areas like gas processing plants crowd during panic, violating 1910.36(e)(2). Oil and gas sees this in 40% of 1910.36 citations, per OSHA's oilfield enforcement logs.

I've seen it firsthand: A Gulf Coast compressor station with inward doors on a room storing H2S monitors and flammable lubricants. During a mock drill, workers piled up—egress time doubled. OSHA flags these under high-hazard occupancy, regardless of actual headcount.

Pro tip: Calculate occupancy via 1910.36(b)—5 sq ft per person net for offices, less for industrial. High hazard? Outward swing mandatory.

Violation #3: Blocked or Improperly Hung Doors

Side-hinged but swinging the wrong way or obstructed by pallets of pipe dope? Common in upstream ops. Doors must open fully with 90-degree swing, no steps or lips impeding per 1910.36(f).

1. Temporary setups on fracking sites use inward doors chained for security.
2. Control rooms exceed 50 souls during turnover meetings, yet doors pull in.
3. Result: Citations stacking with 1910.37 for exit route maintenance.

Oil and Gas Hotspots for 1910.36(e) Trouble

Drilling rigs top the list—cramped quarters, rotating crews pushing occupancy. Midstream facilities like pipelines and LNG terminals follow, with explosive risks demanding outward swings. Downstream refineries? Control centers often violate with inward doors despite 100+ operators.

OSHA's 2022 data shows oil/gas egress violations up 15% post-pandemic, tied to rushed retrofits. Reference NFPA 101 for deeper egress design—it's OSHA's go-to for interpretations.

Avoiding Citations: Actionable Steps for Compliance

Audit now: Map every room-to-exit connection. High-hazard? Flammable limits per 1910.106 define it—don't guess.

Upgrade hardware: Panic bars for outward swing, self-closing hinges. Train crews via 1910.36(g)—post floor plans showing compliant paths.

I've helped sites drop zero citations by swapping one sliding door in a high-hazard mud room. Results vary by site scale, but consistent audits slash risks. Check OSHA's eTool on exits for free checklists.

Stay compliant, stay safe—your crew's egress depends on it.