Understanding OSHA's Two Exit Routes Requirement in Pharmaceutical Manufacturing

The Occupational Safety and Health Administration (OSHA) standard 1910.36(b)(1) is clear: pharmaceutical manufacturing facilities must provide at least two exit routes to ensure the safety of employees during emergencies. This requirement is non-negotiable, yet I've seen many facilities struggle with its implementation.

From my experience, one common mistake is underestimating the distance between the two exit routes. OSHA mandates that these routes be as far apart as practical. In a sprawling pharmaceutical plant, this can mean the difference between life and death during a fire or chemical spill.

Common Misconceptions About Exit Route Placement

Some facility managers believe that simply having two doors on opposite sides of a room meets the requirement. However, this interpretation is too simplistic. The intent of the regulation is to provide alternative escape paths that aren't compromised by the same hazard.

For instance, if a chemical spill occurs near one exit, the second exit should be located far enough away to remain unaffected. I've walked through facilities where both exits were within the same spill containment area, rendering the second exit useless in an emergency.

The Importance of Proper Exit Route Design

Proper exit route design in pharmaceutical manufacturing goes beyond just meeting the letter of the law. It's about understanding the unique hazards of your facility. In my years of consulting, I've seen how the layout of equipment, storage areas, and even the airflow can impact evacuation routes.

One effective strategy is to conduct regular evacuation drills that simulate various emergency scenarios. These drills can reveal hidden flaws in your exit route plan. For example, during a drill at a client's facility, we discovered that a secondary exit was blocked by newly installed machinery, a violation that could have had disastrous consequences in a real emergency.

Ensuring Compliance and Safety

To ensure compliance with 1910.36(b)(1), pharmaceutical manufacturers should:

• Regularly review and update their emergency evacuation plans.
• Conduct thorough risk assessments to identify potential hazards that could affect exit routes.
• Engage safety consultants to perform independent audits of their facilities.
• Implement training programs that educate employees on the location and use of all exit routes.

Remember, while OSHA provides the framework, it's up to each facility to tailor these requirements to their specific operations. Based on available research, individual results may vary, but the goal remains the same: to protect the lives of your employees.

For further guidance, the National Fire Protection Association (NFPA) offers resources on emergency egress and life safety that can complement OSHA's standards. Their insights can help pharmaceutical manufacturers design exit routes that not only comply with regulations but also enhance overall safety.