Any updates on handrail in stairway requirements per latest OSHA standard?

[grahamrigs]

thread507-433966

I was reading this thread and the final result was inconclusive. My stairway is going to be open on both sides and less than 44" wide.

Per OSHA on their website:

1910.29(f)(1)(i) - Handrails are not less than 30 inches (76 cm) and not more than 38 inches (97 cm), as measured from the leading edge of the stair tread to the top surface of the handrail (see Figure D-12 of this section​

1910.29(f)(1)(ii) - The height of stair rail systems meets the following:​

1910.29(f)(1)(ii)(B) - The height of stair rail systems installed on or after January 17, 2017 is not less than 42 inches (107 cm) from the leading edge of the stair tread to the top surface of the top rail.​

1910.29(f)(1)(iii) - The top rail of a stair rail system may serve as a handrail only when:​

1910.29(f)(1)(iii)(A) - The height of the stair rail system is not less than 36 inches (91 cm) and not more than 38 inches (97 cm) as measured at the leading edge of the stair tread to the top surface of the top rail (see Figure D-13 of this section); and​

1910.29(f)(1)(iii)(B) - The top rail of the stair rail system meets the other handrail requirements in paragraph (f) of this section.​

OSHA also provides Table D-2 which says for a staircase <44" wide that's open on both sides:

"One stair rail system each open side."​

However, the OP said at the end that it states in OSHA's FAQ:

Based on the height requirements for stair rails and handrails and the requirements in Table D-2, are both stair rails and handrails required on stairs that have two open sides and are less than 44-in. wide?
Yes. Section 1910.28(b)(11)(ii) Table D-2 contains a printing error, which OSHA will correct in a published notice. For each flight of stairs with two open sides and a width of less than 44 inches, column 4 of Table D-2 should state "One stair rail system with hand rail on each open side" is required. (See 81 FR 82611-12).

This question and answer are no longer in OSHA's FAQ nor has D-2 been updated on their website and I can't find any published notice confirming this quote. Can anyone comment on if there was any clarification on the standard? There are three scenarios here for my staircase:
[ol 1]
[li]Since Table D-2 states that my situation only requires "One stair rail system with hand rail on each open side", then I do not need a handrail at all in my staircase. It does still require stair rails (essentially a guardrail) at 42" in height along the staircase.[/li]
[li]Table D-2 has an error and should state "One stair rail system with hand rail on each open side" meaning that I need a hand rail and a stair rail on both sides. This leads to two possibilities:
[ol a]
[li]A stair rail is required at 42" and incorporates an additional handrail between 30"-38", on both sides.[/li]
[li]A single rail can simultaneously be the stair rail and the handrail if it is between 36"-38" and is able to serve as a handrail (smooth and grippable)[/li]
[/ol][/li]
[/ol]

So are there any recent clarifications on all of this?

 

[JLNJ]

It's a typo. Just put guardrail and handrail on both sides and be done with it.

It the only thing which makes sense. The open sides need guards, it's a stair so it needs a handrail both sides.

 

[canwesteng]

It's clearly a typo, why does a stair with one open side need a handrail with the stair rail, and a stair with two open sides not? I don't think you'd have much of a leg to stand on if OSHA went to fine you. I'd review that clarification with your clients before jumping on it, I've had the discussion where we stated that the old style were clearly not in compliance with OSHA, but that they stated you wouldn't be fined for violations, and they just wanted compliant handrail.

 

[r13]

Rod,

Sorry for my typo and lack of clarity, see corrections made on my original response. Also refer to the pictures and OSHA "enforcement Guidance" posted by dauwerda (right above my response) for details that I wanted to address.

 

[stewbaby]

Thanks all. I'll agree with 'they made a mistake / omission' side of the argument. They clearly want handrails and deem a guardrail at 42" to be too high. Worst case, we spend just a little more money but at least they get the protection on a 'open both sides' as they would on the 'open one side' open side.