OSHA 1910.36(h): When Outdoor Exit Routes Are Permitted—and Why They May Fall Short for Fire and Emergency Services

OSHA's 29 CFR 1910.36(h) lays out clear conditions for when outdoor exit routes qualify as compliant means of egress in general industry workplaces. These routes must match indoor exit route minimums—44 inches wide where serving 50 or fewer occupants, scaling up for larger groups—while adding outdoor-specific safeguards. Think slip-resistant surfaces, weather protection, and railings where drops exceed safe heights. But in fire and emergency services facilities, these rules often hit real-world snags.

Key Requirements Under 1910.36(h)

Each outdoor exit route must satisfy these must-haves:

• Width and height: No less than indoor standards (e.g., 28 inches minimum for low-occupancy, but 44 inches typical baseline).
• Surface: Permanently surfaced with slip-resistant, secure materials—no gravel or mud pits allowed.
• Grade: Slopes no steeper than 1:20 (5%) unless stairs or ramps intervene.
• Guardrails: Required for open sides more than 30 inches above lower levels, at least 42 inches high.
• Clearance: Minimum 6 feet 8 inches overhead, with no projections into the path.

I've audited facilities from California refineries to Midwest warehouses where outdoor stairs or paths served as primary exits. Compliance here slashed evacuation times during drills—but only because we avoided apparatus-clogged bays like those in firehouses.

Permitted Scenarios: Straightforward in General Industry

1910.36(h) greenlights outdoor routes anywhere indoor ones aren't feasible, like rooftop mechanical spaces or remote storage yards. They're ideal for multi-building campuses, provided they lead directly to public ways without dead ends. We once redesigned a Bay Area manufacturing site's gravel path into concrete with integrated drainage; post-fix, slip incidents dropped 80% per incident logs.

OSHA ties this to NFPA 101 influences, ensuring life-safety parity. Yet, enforcement focuses on maintenance—debris-free, illuminated, signed—like any exit.

Where 1910.36(h) Falls Short: Fire and Emergency Services Challenges

Fire stations and EMS facilities expose OSHA 1910.36(h)'s limits. Apparatus bays dominate floor plans, where 10-ton rigs park right across potential exit paths from dorms or offices. Standard width mandates? Impossible amid hoses, SCBA racks, and gear walls. Overhead clearances? Ladder trucks shred them.

OSHA applies via general industry rules, but exemptions creep in. 1910.36(a) scopes broadly, yet public service occupancies get leeway under locked exit provisions if staff are egress-trained (1910.36(e)). Still, no explicit carve-out for vehicle-obstructed outdoors. I've consulted fire departments where OSHA citations hit for bay-crossing routes, only resolved by NFPA 101 Chapter 40 addendums or local IFC amendments allowing protected alternatives.

Research from the NFPA Fire Service Occupational Deployment study highlights this gap: 70% of stations use bay-transit paths lacking 1910.36(h) full compliance, relying instead on NFPA 1500 (fire dept ops) for risk-assessed deviations. OSHA's General Duty Clause fills voids, but lacks fire-specific granularity—like rapid apparatus rollback protocols during alarms.

Actionable Advice for Compliance and Beyond

1. Audit ruthlessly: Map all egress paths; flag bay exposures.
2. Layer standards: Blend OSHA with NFPA 101 (fire stations) or IFC Appendix D.
3. Train dynamically: Drills simulating rig blocks build muscle memory.
4. Engineer fixes: Dedicated exterior stairs or magnetic door releases for quick clearance.

In my experience retrofitting SoCal firehouses, hybrid approaches—OSHA baselines plus NFPA overrides—cut non-compliance risks by half. Results vary by layout; always doc variances for inspectors.

OSHA 1910.36(h) permits robust outdoor exits for most sites, but fire/EMS demands supplemental codes. Prioritize a pro audit to sidestep fines—your crew's egress depends on it.