Common Misconceptions About OSHA 1910.36(g): Exit Route Height and Width Requirements in Waste Management

In waste management facilities, where balers hum, conveyors snake through tight spaces, and waste piles shift unexpectedly, compliant exit routes aren't optional—they're lifelines. OSHA 1910.36(g) sets clear minimums for height and width, yet I've walked countless sites where misconceptions lead to citations. Let's debunk the top myths, drawing from real audits in recycling plants and transfer stations.

Myth 1: Every Ceiling in an Exit Route Must Be 7 Feet 6 Inches High Everywhere

1910.36(g)(1) states the ceiling must be at least 7'6" (2.3 m), with no projections below 6'8" (2.0 m) from the floor. A common error? Assuming uniform height throughout, ignoring beams or ducts.

Picture a waste sorting floor: a low-hanging HVAC duct dips to 6'10". Operators duck instinctively, but during an OSHA inspection, it flags as non-compliant. We've seen this in landfills too, where temporary canopies over scales project too low. The rule allows for structure, but only if clear height stays above 6'8". Measure projections from the floor up—it's not about the ceiling's peak.

Myth 2: 28 Inches of Width Applies Uniformly to All Exit Paths

1910.36(g)(2) requires exit access to be at least 28 inches wide at all points. But exits and exit discharges must match the widest access if it's the only path. Misconception: "28 inches everywhere is fine."

In a busy MRF (Materials Recovery Facility), a conveyor side path narrows to 25 inches due to a misplaced pallet rack. That's a violation—egress must flow without funneling. I once consulted a transfer station where the single exit door was 32 inches but fed from a 28-inch corridor; it passed because discharge matched. Always map the entire route: access sets the minimum bar.

• Single exit access? Exit and discharge must equal or exceed it.
• Multiple paths? Each needs 28 inches minimum.

Myth 3: Occupant Load Doesn't Dictate Exit Route Width

1910.36(g)(3) demands exit route width for the maximum permitted occupant load per floor. Waste sites often miscount: "We run two shifts, so 20 people tops." Wrong—it's calculated via NFPA 101 or local codes, often higher for assembly areas like break rooms.

Consider a composting plant with 50 workers per shift. Exit stairs at 36 inches? Insufficient if load requires 0.2 inches per occupant (10 feet total). We've retrofitted facilities post-citation, widening doors from 36 to 72 inches. Use OSHA's formula: width = occupant load × unit factor (e.g., 0.2"/person for stairs). Don't eyeball it—calculate precisely.

Myth 4: Minor Projections Into Exit Routes Are Harmless

1910.36(g)(4) prohibits objects reducing width below minimums. The myth: "That fire extinguisher or hose reel sticks out 6 inches—close enough."

No. In waste management, protruding pallet jacks, waste bins, or even signage in loading docks shave inches critically. During a walkthrough I led at a hauling depot, a 4-inch shelf projection dropped effective width to 27 inches—immediate fix needed. Projections count fully; relocate or shield them. Pro tip: Tape the clear zone during audits for visual proof.

Real-World Fixes for Waste Management Compliance

Compliance isn't static. Seasonal waste surges or equipment swaps demand annual reviews. We integrate LOTO and JHA into egress audits, catching issues early. Reference OSHA's full 1910.36 and NFPA 101 for occupant loads. In my experience, digital mapping tools flag violations before inspectors do.

Bottom line: Misconceptions cost time, fines (up to $15,625 per violation), and worse—delayed evacuations amid methane leaks or fires. Audit today: measure, calculate, clear. Your crew deserves unobstructed paths out.