OSHA 1910.36(g) Exit Dimensions: When They Fall Short in Hospital Settings

OSHA's 1910.36(g) sets baseline dimensions for exit routes: ceilings at least 7 feet 6 inches high, projections no lower than 6 feet 8 inches, exit access minimum 28 inches wide, and overall widths scaled to occupant load. These rules anchor general industry compliance. But in hospitals, where patient beds, gurneys, and medical equipment define daily operations, these specs often prove inadequate.

Does 1910.36(g) Apply to Hospitals?

Straight answer: yes. Hospitals fall under OSHA's general industry standards (29 CFR 1910), with no blanket exemption for healthcare. I've audited facilities from California clinics to East Coast trauma centers, and OSHA inspectors cite 1910.36 violations routinely if exits cramp up. That said, the standard explicitly requires widths "sufficient to accommodate the maximum permitted occupant load" under (g)(3), pushing hospitals beyond the 28-inch floor.

Hospitals calculate occupant loads differently—typically 200 square feet per person in patient areas per NFPA methodologies OSHA references indirectly. A 10,000 sq ft ward? That's 50 occupants, but factor in non-ambulatory patients, and your egress math explodes.

Where 1910.36(g) Falls Short: Real-World Hospital Gaps

Start with width. A 28-inch exit access? Fine for office workers filing out single-file. In hospitals, try wheeling a gurney through that—needs at least 68 inches clear for a standard stretcher (per NFPA 101, Section 7.3.4). I've seen retrofitted hospitals where OSHA-min corridors bottlenecked during drills, turning evacuations into chaos. New hospitals demand 96-inch corridors under NFPA 101 Chapter 18; existing ones get 80 inches minimum. OSHA's 28 inches is the absolute floor, but it ignores healthcare realities.

• Projections and obstructions: (g)(4) bans reductions below minimums, yet hospital IV poles, carts, and door swings routinely nibble at space. Ceiling projections at 6'8" clearance? Heads-up for tall staff or overhead equipment.
• Ceiling height: 7'6" works for factories, but hospital ceilings often hit 9-10 feet to handle HVAC, lights, and sprinklers without impeding oxygen tanks or lifts.

Occupant load under (g)(3) amplifies this. Hospitals aren't sprinting crowds; they're slow-moving convoys of beds. Egress capacity factors in flow rates—1.0 inch per occupant for level components becomes irrelevant when patients can't self-evacuate.

When 1910.36(g) Effectively "Doesn't Apply": NFPA 101 and CMS Override

Here's the pivot: OSHA doesn't operate in a vacuum. Hospitals under Medicare/Medicaid certification must meet CMS Conditions of Participation (42 CFR 482.41), which mandate NFPA 101 Life Safety Code compliance. OSHA's own interpretations—like the 1994 directive CPL 02-00-049 and letters to AHA—state that NFPA 101-conformant facilities generally satisfy 1910.36.

In practice, this means 1910.36(g) recedes when:

1. Local AHJ (Authority Having Jurisdiction) enforces stricter building/fire codes: California Title 24 or IBC often supersedes with hospital-specific widths (e.g., 8 ft corridors).
2. Existing vs. new construction: NFPA 101 Chapter 19 allows 6'8" for existing healthcare corridors, still beating OSHA's 28 inches, but only if AHJ approves.
3. Specialized areas: OR suites or psych wards may use NFPA exceptions for horizontal exits or smoke compartments, sidestepping standard route widths.

Bottom line? 1910.36(g) applies as the legal minimum, but it "falls short" or yields to NFPA 101 in hospitals because patient vulnerability demands it. Research from NFPA reports shows code-compliant hospitals cut evacuation risks by 40-60% over bare OSHA mins.

Actionable Steps for Hospital Safety Teams

Measure your exits today—laser tools beat tape for projections. Cross-check against NFPA 101 (free viewer at nfpa.org) and run occupant load calcs using Appendix A tables. We once flagged a 32-inch corridor in a SoCal ER; widening it prevented a Joint Commission tag. Consult your AHJ early—fire marshals often blend OSHA/NFPA in inspections. Balance this: while NFPA adds rigor, overkill can strain budgets, so prioritize high-risk zones like ICUs.

Stay compliant, stay safe. Hospitals save lives—don't let narrow exits undo that.