Common Mistakes with OSHA 1910.36(h) Outdoor Exit Routes in Maritime and Shipping

OSHA 1910.36(h) sets clear rules for outdoor exit routes: they must match indoor route dimensions—at least 7 feet 6 inches high and 28 inches wide—while adding weatherproof surfaces, slip resistance, railings for drops over 30 inches, and protection from hazards like ice or water accumulation. In maritime and shipping ops, where docks, terminals, and gangways face constant salt spray, tides, and cargo hustle, these rules get bent or ignored. I've walked countless port facilities where a simple oversight turns an exit path into a lawsuit waiting to happen.

Mistake #1: Skimping on Dimensions for 'Marine Flexibility'

Teams often narrow outdoor paths to squeeze in forklifts or pallet jacks, thinking maritime chaos excuses it. Nope. 1910.36(h)(1) demands the full indoor specs, no exceptions. On a Long Beach dock I audited, a 24-inch gangway exit was 'standard' until a worker's shoulder caught the edge during an evacuation drill—pure violation.

Related regs like 29 CFR 1917.122 for marine terminals reinforce this: exits must stay clear and dimensionally compliant. Fix it by measuring every route annually and marking no-go zones for gear.

Mistake #2: Ignoring Slip-Resistant Surfaces in Wet Environments

Water, oil, fish guts—you name it, shipping surfaces collect it. Yet 1910.36(h)(2) requires slip-resistant materials on sloped or slick spots, and routes free of standing water. Common blunder: grated metal walkways without grit coatings, turning rainy days into skating rinks.

• Pro tip: Use OSHA-approved anti-slip tapes or epoxy coatings rated for marine corrosion.
• Check 1918.95 for longshoring gear that can't block these paths.

In one San Diego terminal, we retrofitted exits post-incident; slips dropped 40% per their logs. Research from NIOSH backs this—wet surfaces spike falls by 55% in industrial settings.

Mistake #3: Overhead Hazards from Cranes and Cargo

1910.36(h)(3) mandates overhead clearance matching indoor routes, but ports love suspending loads over walkways. A swinging pallet or crane boom? Instant violation. I've seen it on vessel ramps where low booms clip helmets—narrow misses that scream non-compliance.

Maritime twist: Tidal swings alter heights, so routes must account for low tide lows. Reference USCG regs alongside OSHA for vessel-to-dock transitions. Solution? Install height indicators and enforce 'no-load-over-path' policies with spotters.

Mistake #4: Forgetting Railings and Drop Protection

Docks drop into water faster than you can say 'man overboard.' 1910.36(h)(4) requires railings on any edge over 30 inches—standard 42-inch height with midrails. Mistake? Treating pier edges as 'natural barriers.'

Short para punch: One foggy Oakland night, a fatigued longshoreman stepped off an unrailed exit. He survived; your team might not. Pair with 1917.112 for vehicle barriers.

Mistake #5: Poor Maintenance and Lighting Oversight

Routes must be maintained (1910.36(h)(5)), with illumination per 1910.37(b)(6)—one foot-candle minimum. In shipping, debris piles up, lights corrode from salt air, and ice forms unchecked. Anecdote: We flagged a Vancouver yard where snow-covered exits lacked de-icing plans, violating the 'free from ice/snow' clause.

Balance note: While these fixes curb 80% of egress issues per BLS data, extreme weather can challenge even compliant setups—hence regular drills. For deeper dives, consult OSHA's full 1910.36 text or NSC maritime guides.

Bottom line: Audit your outdoor exits quarterly, train crews on specifics, and integrate into JHA processes. Maritime safety isn't optional—it's the edge between smooth ops and headlines.