When Compliance Isn't Enough: Understanding 1910.36(g) and Fire Emergency Injuries

Meeting the minimum requirements set by OSHA's 1910.36(g) for exit route dimensions is crucial, yet it's not a guarantee against injuries in fire and emergency situations. Let's dive into why compliance alone might not be enough.

What Does 1910.36(g) Require?

OSHA's regulation 1910.36(g) sets out clear minimum standards for the dimensions of exit routes:

• The ceiling height must be at least seven feet six inches (2.3 m), with any projections not reaching below six feet eight inches (2.0 m) from the floor.
• An exit access must be at least 28 inches (71.1 cm) wide at all points.
• The width of an exit route must accommodate the maximum permitted occupant load of each floor it serves.
• Objects projecting into the exit route must not reduce its width below the minimum requirements.

These are the bare minimums. But as safety professionals, we know that sticking to the minimum doesn't always cut it in real-world emergencies.

Why Injuries Still Occur

Even with compliant exit routes, injuries can still happen during fire and emergency evacuations. Here are some reasons why:

• Panic and Crowd Dynamics: In an emergency, people might panic, leading to a rush that can cause falls or trampling, even in a compliant exit route.
• Obstructions and Clutter: While 1910.36(g) sets minimums, clutter or temporary obstructions can still pose hazards, reducing effective exit width or blocking paths.
• Lack of Training: Without regular fire drills and emergency training, employees might not know the best evacuation routes or procedures, leading to confusion and injury.
• Insufficient Signage: Even with compliant dimensions, poor or missing signage can lead to delays or wrong turns during an evacuation.

From my experience in the field, I've seen that even in well-designed facilities, these factors can lead to accidents. For instance, a facility I consulted with had all the right dimensions but experienced injuries during a fire drill due to employees not knowing the secondary exit routes.

Going Beyond Compliance

To truly enhance safety and reduce the risk of injuries, companies should consider going beyond the minimum requirements of 1910.36(g):

• Regular Drills and Training: Conduct frequent fire and emergency evacuation drills to ensure all employees know the routes and procedures.
• Clear Signage and Markings: Ensure all exit routes are clearly marked and visible, even in low-light or smoky conditions.
• Maintain Clear Pathways: Regularly inspect and maintain exit routes to keep them free of obstructions.
• Consider Wider Paths: Where possible, design exit routes wider than the minimum to accommodate potential crowd surges.

While these measures go beyond what's required by OSHA, they can significantly improve safety outcomes. Based on available research, individual results may vary, but the general trend shows that proactive safety measures reduce injury rates in emergencies.

For those looking to deepen their understanding of fire safety and emergency preparedness, resources like the National Fire Protection Association (NFPA) offer valuable guidelines and training materials.