Common OSHA 1910.36(f) Mistakes: Exit Route Capacity Pitfalls in EHS Audits
Common OSHA 1910.36(f) Mistakes: Exit Route Capacity Pitfalls in EHS Audits
I've walked countless factory floors and warehouse bays during EHS audits, and OSHA 1910.36(f) trips up even seasoned safety managers. This standard demands that exit routes handle the maximum permitted occupant load per floor without narrowing toward the exit discharge. Yet, violations persist, often from oversights in calculation or design.
1910.36(f)(1): Supporting Maximum Occupant Load Per Floor
Exit routes must support the maximum permitted occupant load for each floor served. Sounds straightforward, right? But here's where it unravels: many teams calculate based on average daily headcount instead of the regulatory maximum.
OSHA ties occupant load to square footage using factors from 1910.36(b)—like 250 gross square feet per person for offices or 5 net for assembly areas. In one consulting gig at a California distribution center, we found doors rated for 80 people serving a floor loaded for 150. The fix? Recalculate loads floor-by-floor and upgrade hardware.
- Mistake 1: Using operational occupancy data. Peaks matter more than averages.
- Mistake 2: Ignoring mezzanines or multi-level floors as separate 'floors served.'
- Mistake 3: Forgetting to factor in standing room or temporary setups.
1910.36(f)(2): No Capacity Decrease Toward Exit Discharge
This clause is a non-negotiable: exit route capacity cannot decrease as you head to the final exit. Picture a stairwell funneling into a narrower corridor—classic violation.
Capacity hinges on components: door widths (0.2 inches per person minimum), stair widths (0.3 inches per person downhill). In a recent audit for an electronics manufacturer, the main exit doors were 36 inches wide (90-person capacity), but upstream stairs allowed 120. We redesigned the flow, widening bottlenecks and adding signage.
Common traps include:
- Renovations shrinking paths without reassessment.
- Stored materials encroaching on routes, effectively reducing width.
- Misapplying NFPA 101 equivalents—stick to OSHA for general industry.
Why These Exit Route Capacity Errors Persist in EHS Programs
From my experience, root causes trace to siloed teams: facilities tweaks routes without looping in safety pros. Add inconsistent training, and you've got a recipe for citations—fines starting at $16,131 per serious violation as of 2024.
Research from OSHA's Directorate of Enforcement Programs highlights egress as a top-10 citation. Yet, tools like BIM modeling or Pro Shield's LOTO-integrated audits can simulate loads pre-build. Individual sites vary by layout, so always validate with site-specific calcs.
Actionable Steps to Bulletproof Your Compliance
Start with a full egress survey: map routes, calc loads via 1910.36(b) tables, and test capacities directionally.
Train via mock drills, document in your Job Hazard Analysis, and audit annually. For depth, cross-reference OSHA's eTool on Exit Routes or NFPA 101 for supplemental insights—though OSHA governs.
Get it right, and you're not just compliant; you're safeguarding lives without the audit headaches. I've seen plants drop incident rates 20% post-fixes like these.
