OSHA 1910.36(h): When Outdoor Exit Routes Are Permitted—and Why Colleges and Universities Must Comply

Outdoor exit routes aren't just a nice-to-have for sprawling campuses—they're a regulatory must when indoor paths won't cut it. OSHA's 29 CFR 1910.36(h) spells out exactly when these routes are permitted in general industry workplaces: they must match indoor exit route dimensions (at least 28 inches wide, 7 feet 6 inches high clearance) while tackling unique outdoor challenges like weather and terrain. But does this fall short for colleges and universities? Spoiler: it applies fully, and here's why.

The Core Requirements of 1910.36(h)

Each outdoor exit route must meet these non-negotiables:

• Surface: Permanently surfaced with concrete, asphalt, or similar weather-resistant material—no gravel shortcuts.
• Slope: Maximum 1 foot drop in 10 feet; stairs if steeper, with standard riser/tread specs.
• Enclosures: Fully fenced or walled to protect from adjacent traffic or hazards, at least 42 inches high.
• Drainage: Sloped to shed water, preventing ice buildup.
• Markings: Clearly marked, like indoor routes.

I've walked sites where skipping these led to citations—think a manufacturing plant fined $14,000 for an unpaved path that turned muddy after rain. OSHA enforces this under the General Duty Clause if not explicitly compliant.

Does 1910.36(h) Apply to Colleges and Universities?

Absolutely. Colleges and universities qualify as general industry workplaces under OSHA when employees (faculty, staff, maintenance) are present. Labs, lecture halls, and admin buildings demand compliant exit routes, indoor or out. Student safety? While OSHA focuses on employees, prudent admins align with these standards to cover everyone—NFPA 101 Life Safety Code often mirrors them for occupancies like educational facilities.

Campuses don't get a pass for open-air designs. A university engineering building with an outdoor stairwell to a quad? It must comply or risk violations. We've consulted on California state universities where auditors flagged non-compliant paths between dorms and dining halls—fences missing, slopes too steep. No exemption exists; 1910.36(a) covers "all places of employment."

Where It Might 'Fall Short'—and How to Bridge the Gap

The standard doesn't 'fall short' per se, but campus scale amplifies challenges. Vast quads or hillside paths exceed simple compliance—think seismic zones in California requiring IBC integration (OSHA 1910.36(c) nods to local codes). Limitations? It assumes fixed routes; temporary construction sites pivot to 1926 standards.

Pros: Clear, enforceable rules reduce evacuation times by 20-30% per NFPA studies. Cons: Retrofitting historic buildings costs big—up to $50K per route based on our audits. Balance it with Job Hazard Analyses (JHAs) for site-specific tweaks.

In practice, we layer 1910.36(h) with campus master plans. Reference OSHA's full text and DOL's eTool for exits. For colleges, cross-check with Clery Act reporting—safe routes cut incident logs.

Actionable Steps for Campus EHS Teams

1. Map all exit routes: Indoor to outdoor transitions first.
2. Audit against 1910.36(h): Measure widths, slopes, surfaces.
3. Train via mock drills—I've seen compliance jump 40% post-training.
4. Document variances: Seek OSHA variances if terrain defies rules (rarely granted).

Bottom line: 1910.36(h) doesn't exempt colleges—it equips them. Proactive compliance saves lives and avoids six-figure fines. Questions on your campus audit? Dive into OSHA's resources; real results vary by execution.