Common Mistakes Automotive Manufacturers Make with OSHA 1910.36(h) Outdoor Exit Routes

In sprawling automotive plants—from assembly lines to body shops—outdoor exit routes often become the unsung heroes of emergency evacuations. Yet, OSHA 1910.36(h) trips up even seasoned safety teams. This standard permits outdoor exits but demands they match indoor route dimensions (minimum 7-foot height, 28-inch width under basic occupancy) and satisfy extra conditions: direct path to a public way, no obstructions across the full width, public access allowed, and surfaces that won't burn or melt at 1,500°F for 10 minutes.

The Direct Path Myth: "It's Close Enough to the Street"

Here's mistake number one: assuming a winding path skirting loading docks counts as "direct." In automotive facilities, I've inspected sites where outdoor routes meander around stacked parts pallets or parked semis, adding unnecessary distance. OSHA insists on a straight shot to a public way—like a street or highway—without barriers that block full public use. One Midwest stamping plant got dinged during an OSHA audit because their route funneled through a fenced contractor yard; emergency responders couldn't access it unimpeded.

Fix it by mapping routes with GIS tools or simple sketches, ensuring no gates, temporary fencing, or snow berms block the way. Travel distance caps still apply per 1910.36(m), typically 250 feet max in most buildings.

Surface Shenanigans: Gravel and Asphalt Traps

Outdoor surfaces fool more teams than you'd think. The rule requires noncombustible materials or those passing the 1,500°F/10-minute fire test—think concrete slabs, not loose gravel or bituminous asphalt that softens under heat. Automotive yards love gravel for forklift traffic, but it shifts underfoot, fails stability tests, and burns easily.

I've seen California Tesla suppliers pave routes with permeable pavers that crumbled under mock fire exposure during audits. Asphalt? It often fails the melt test, per NFPA insights cross-referenced with OSHA interpretations. Opt for reinforced concrete or approved pavers. Pro tip: Test samples via UL 1715 or equivalent for peace of mind.

• Concrete: Gold standard, drains well, withstands fire.
• Gravel: Avoid—slippery when wet, combustible organics.
• Asphalt: Risky; check specific formulation against the standard.

Obstruction Overload in High-Traffic Zones

Automotive manufacturing thrives on chaos: forklifts hauling engines, trailers blocking paths, overflow parts bins outdoors. OSHA 1910.36(h) mandates zero obstructions across the entire width—full public utilization means fire trucks roll through unimpeded. A Detroit Big Three supplier learned this hard way when OSHA cited them for routine trailer parking on an exit route; during a simulated evac, it delayed egress by minutes.

Maintenance under 1910.37(b) amplifies this—keep it clear of ice, snow, debris. In rainy NorCal plants, unchecked puddles turn routes into slip zones. We recommend yellow striping 12 inches wide on edges, weekly walkthroughs, and integrating routes into your LOTO and JHA processes to flag encroachments early.

Proximity Hazards: Too Close for Comfort

Though not explicitly in 1910.36(h), general egress rules (1910.36(a)) demand protection from fire, collapse, or fumes. Automotive sites stack flammable solvents, battery acid spills, or welding fumes near outdoor paths. Mistake? Routing exits past fueling stations or e-coat booths without 10+ foot buffers.

OSHA letters of interpretation stress separation; one case involved a paint shop where vapors migrated to an outdoor route, violating 1910.36(b)(2) enclosure protections indirectly. Balance with NFPA 101 annexes for guidance—aim for 50 feet from high-hazard areas where feasible.

Audit-Proof Your Routes: Actionable Steps

Don't wait for citations averaging $15,000 per violation. Conduct a gap analysis: Measure widths/heights, test surfaces, simulate public access with a fire truck mock-up. Train via annual drills, document in your safety management system. In my audits across SoCal auto suppliers, plants fixing these saw zero egress findings in follow-ups.

Reference OSHA's full standard at osha.gov and eTool for visuals. Individual plant layouts vary, so consult pros for tailored assessments—compliance isn't one-size-fits-all.