Safety Tidbit #23 - Outdoor Emergency Exits

Way back in Safety Tidbit #8, I presented a fair amount of information about emergency exits and routes to the exit.  This week, I had another interesting question at a site so I decided to spend a little time on one very specific part of the OSHA standard on emergency exits.  Specifically, 1910.36(h), Outdoor exit routes.  However, before I begin, let us remember that 1910.36(c)(1) requires that each exit discharge must lead directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside. Also remember, we want to get everyone out as quickly and safely as possible.

The scenario we have is a large manufacturing facility basically a large square building with an open area inside for the production processes.  Exit doors are located every 20 feet or so around three sides of the building and the front has administrative offices and the main entrance for visitors.  However, the exits on the other three sides leading from the production areas lead to the grass outside or to the parking lot. So, you ask, what is the problem.  I noticed some of the doors were labeled as exits and some were not.  However, all were accessible and had clear paths to them.  I asked the client why some were labeled and some were not.  They said a “reputable source” told them that because the ground outside was not at the same level as some of the doors and not level they could not be considered an emergency exit.  The exit doors were about six inches below the level of the grass outside and the at some doors slanted to one side or the other of the exit.  They were cited under 1910.36(h)(3) that the outdoor exit route must be reasonably straight and have smooth, solid, substantially level walkways.

I did not wish to degrade the “reputable source” aka OSHA so, walking through 1910.36(h), I recommended to the client to do the following to ensure employees are able to egress from all of the doors:

            1910.36(h)(1) – as none of the doors are higher than 4 four feet above the ground no guardrails are necessary.

            1910.36(h)(2) – Ensure snow or ice are prevented or removed to prevent slipping hazards.

            1910.36(h)(3) – Install a concrete pad outside each exit to give a place in front of the door that is at the same height and level with the exit door.  This will also give an area that can be kept clear of snow or ice.

This may seem like overkill but when you consider there are approximately 100 people at the facility, in an emergency getting out is most important and the more exits available the better.