API vs OSHA 3

[MotoAce51]

Good Morning;

I am not even sure if this would be in the right section, but it has to do with production tanks. I have a question that I have been trying to answer through searching and talking to people but I can't seem to get two sources to match. I am looking at the specs for API vs OSHA regarding catwalks & stairways for Oil Production Tanks.

What is the difference in the API and OSHA specs? How can API be different than OSHA yet still comply? From what I can find, OSHA is very similar but a stricter standard.

 

[IFRs]

Comply with OSHA. You will then be in compliance with API.

 

[Duwe6]

OSHA - and use 1¼" or 1½" pipe for handrailing. The minimum OSHA-approved angle size is HUGE.

 

[MotoAce51]

Right now my company is just manufacturing production tanks. We were going to outsource the walkways & stairways. Some customers just want cheap API minimum requirements, and others are requesting OSHA. The more I search around I see some companies saying, "Walkways and stairways are built to API specifications and are OSHA compliant." The question arose when I went to confirm OSHA compliant & seeing the material for these the railing was made from is 10-12ga angle. Hence the question, how can companies claim OSHA compliant if the railings are small?

 

[IFRs]

Ask them, you may not like the answer.

 

[JStephen]

The answers get complicated.
OSHA specifies minimum handrail sizes and spacing. But they also specify required loads, and if you use posts closer together or use other bracing, you can vary the handrail size accordingly.
OSHA also has the old traditional rules which are in the current CFR and has published "proposed rules" which may also be followed, and that complicates the issue considerably. For example, stairway railing heights that were mandatory under the "old" rules are prohibited under the "new" rules, which doesn't make a lot of sense.

 

[IFRs]

JStephen - Can you post the CFR references? I have sent in technical inquiries to OSHA regarding industrial stairway railing heights and received nothing in 2 years. there are several interpretations published but they were not conclusive. Maybe I'm reading in the wrong places?

 

[MotoAce51]

JStephen, that's pretty much the answer that I was expecting. Everyone who writes these official publications makes sure it's very "legal" in the way they are written. So many "gray" areas. One I found yesterday on stairways said the required run is 8.75" and rise is 8.75" for steps. But just before the chart, it says "the requirement is as follows. But is not limited to these values." (Or something along these lines). So basically, you must meet this requirement, but your not limited to it.

The big issue were having at my company is getting people to pay more for "better" walkways. Most customers want the bare minimum (cheap). I think they have the mindset "if I save enough on walkways, I can buy an extra tank." For them, tanks = money, walkways = nothing. I could be wrong, but it's what it seems.

 

[IFRs]

Safety = money but only when it is not safe and someone gets hurt. Then it is lots of money. Unsafe is stupid, shortsighted and risky. Once you bring up the safety aspect and the need to minimize financial risk, compliance with OSHA looks pretty good to most managers since it will be there butts on the line when someone gets hurt and it is found out that they built something not OSHA compliant.

 

[JStephen]

This is the 2013 CFR that includes OSHA regulations for "General Industry":

http://www.gpo.gov/fdsys/pkg/CFR-2013-title29-vol5/pdf/CFR-2013-title29-vol5-part1910-subpartD.pdf

This is the same standard on the OSHA website:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9715

Refer to page 9 on the pdf in the first link, and you find, "A stair railing shall be of construction similar to a standard railing but the vertical height shall be not more than 34 inches nor less than 30 inches from upper surface of top rail to surface of tread in line with face of riser at forward edge of tread."

This is an OSHA publication from 2003 (actually newer than the "old" rules above):

https://www.osha.gov/Publications/osha3124.pdf

On Page 9 of this publication, you find "Stair rails installed after March 15,1991, must be not less than 36 inches (91.5 cm) in height."

So whatever conforms to the official OSHA publication violates their own rules and vice versa.

From this page:

https://www.osha.gov/as/opa/proposed-rulemaking-factsheet.html

"In 1973, OSHA published a proposed revision of subpart D that was withdrawn in 1976 because, in the Agency's view, it had become outdated and did not reflect then-current information. In 1990, OSHA published another proposed rule to reorganize, update, and clarify the subpart and add personal fall protection requirements to subpart I, which regulates personal protective equipment. In 2003, the rulemaking record was reopened and several issues were raised. Comments to the record indicated that the 1990 proposed rule was outdated and did not give adequate consideration to newer technology. In 2005, the decision was made to completely redraft the proposed rule. The 1990 proposal was not withdrawn, and therefore is still on record today as a proposed rule."

Not stated here, but stated elsewhere, is that OSHA considers compliance with a proposed rule that violates an actual rule to be a "de minimis violation" that will not be cited or fined. So it's not necessarily a big deal from an employer's standpoint, but makes it awkward if you're selling the stairway.

 

[IFRs]

This is exactly the issue I sent in a written inquiry for. No response after 2 years. I gave up and just make industrial stairs 36" unless I'm copying an old set of drawings at 34" in which case they get 34". I'm good with the safety of both.