handrail requirements per latest OSHA standard 7

[mcdermott2]

I have a question regarding handrails on platforms per the latest OSHA requirements. Typically I have been designing the top rail of a stair rail system to serve as both a top rail and handrail. As of January 17, 2017, per OSHA, it appears as if the top rail of a stair rail must be >= 42” from leading edge of a stair, while the height of a handrail must be 30” <= x <=38”. If this is correct, it seems to me that for a stair rail system I would need a top rail, mid rail, toe board, and now an additional hand rail. Below are the pertinent sections from OSHA. Do you all agree with this interpretation?

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)(A)
The height of stair rail systems installed before January 17, 2017 is not less than 30 inches (76 cm) from the leading edge of the stair tread to the top surface of the top rail; and

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

 

[JStephen]

I believe that is correct.

 

[WinelandV]

mcdermott2,

I was looking at this in December, and that is the conclusion that we reached in the office. Note that the handrails will now push into the tread area (unless your guardrail is off the side of your stringer), so a 20" wide tread becomes even more narrow.

 

[mcdermott2]

Thanks for the responses! It looks like I will indeed need to add an additional hand rail into my design.

 

[stewbaby]

Anyone contacted OSHA for an interpretation on this to be sure? I read the same thing you guys do, but ouch...especially on tank stairs.

 

[JLNJ]

Maybe it's out there and I haven't seen it, but OSHA doesn't say that the rails can "push into" the stair width.

This "encroachment" is explicitly defined in the model codes, but (no surprise) not addressed in OSHA. I take the OSHA width to mean in/in rails or stringers, or guards, or whichever is greater.

 

[IFRs]

Why is a single rail at 36" to 38" not acceptable by itself? It is not subject to the date limitation in 1910.29(f)(1)(ii) because it is a separate clause (iii). Has anyone seen an interpretation of this?

 

[WinelandV]

IFR,

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.

Link

 

[IFRs]

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.

Doesn't this say if the handrail is 36 to 38 inches high and meets the other requirements of a guardrail then as a single rail system it can be both a hand- and a guard- rail?

 

[CarlB]

My interpretation agrees with IFRs's, that a top rail at 36"-38" height serves as both a handrail & stair rail.
That relies on 1910.29 (f)(1)(iii)(A)-(B), that allows it, if it meets other HANDRAIL requirements in paragraph (f). The requirement for 42" minimum height is not for a handrail, but a "stair rail system". So 36"-38" trumps the 42" requirement. Also, Fig. D-13 shows the single top rail at the 36"-38" height.

Would be good to get clarification from OSHA directly.

 

[JLNJ]

It only makes sense that, if you are high enough to need a 42" guardrail on a flat surface, you need a 42" guardrail to guard the edge of a stair. If you need a 42" guardrail you need a lower rail on the stair to grasp. It seems to me that this is the intent.

 

[IFRs]

If the hand rail is 36" to 38" at the nose of the tread, and if the stairway is on a 45 degree angle, the rail at the middle of the tread is higher. Of course, one could argue the reverse that on the downside the rail is lower. I also think that a person is more likely to trip up or fall down the stairs rather than sideways and won't get as much of a running start as on a flat surface so the railing may offer adequate protection at the 36" to 38" height. OSHA refers to NFPA 101 which seems to say that single rails are OK. I tend to think in terms of spiral stairways that go around large storage tanks...

 

[mcdermott2]

IFR and CarlB -

Below is a re-hash of my interpretation which is at odds with what you two are saying:
The following is required for platforms installed after Jan 17, 2017:

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.​

This means that the top rail must be at least 42" from leading edge of the stair tread. As such, the following provisions no longer can apply because they require the top rail to be between 36 and 38" from top of stair tread:

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.
​

Essentially, 1910.29(f)(1)(ii)(B) says that the top rail must be >42". 1910.29(f)(1)(iii)(A) says that a top rail can serve as a handrail only if the top rail is between 36" and 38".

Because the top rail has to be a min of 42" it cannot serve as a handrail (at least that is my interpretation). Feel free to refute what I have written above -- I would love to be convinced that I don't need the extra hand rail!

 

[IFRs]

An official interpretation is needed. I truly hope one is forthcoming. In the meantime, let's not interpret the language, let's read it literally, in the order that it was written, paying attention to the paragraph numbering system, grammar, etc. I like to believe that intelligent and hardworking people wrote and word-smithed it carefully. None of the clauses are there to be ignored. If they say that the top rail of a stair rail system is 42" +/- 3" tall and follow that in another section by saying that hand rails can be considered top rails if they meet some guidelines I don't see that as a contradiction or something that can be ignored but simply another statement. Note that top rails are allowed to exceed 45" under certain circumstances which does not contradict the 42" +/- 3" requirement but modifies it. It's like saying "roads are for cars" and then "bicycles can use roads if they ride on the right". You don't ignore the second statement or consider it to be moot in light of the first. Bicycles are not banned from roads and bicycles being on roads does not mean it is not considered a road. Yes, the top rail of a stair rail system is nominally 42" +/- 3" tall. As delineated in other sections, the stair rail system consists of two rails - a top or guard rail and a lower hand rail. They serve different functions and have different qualities including height above the tread. Equally clear (to me anyway) is the statement that a hand rail which is required to be between 30" and 38" but is actually between 36" and 38" can be considered the top rail of a stair rail system. They are saying that a single rail can be used for a stair rail system under certain conditions, that the top rail can be considered a hand rail and it is not necessary to have both guard- and hand- rails under these conditions. They deliberately included section (f)(1)(iii) in the code, and expected readers to read it and follow it, otherwise it would simply not be there. If the top rail was never to vary from 42" then there would be only one statement. But, top rails can be +/- 3" and also over 45" under certain conditions. If the hand rail was to only be between 30" and 38" above the tread then there would be no other clause. There are often exceptions to a rule and in this case they made it perfectly clear what this exception is. Note that there is no cutoff date or other qualification for this.

A literal reading of the code following carefully the order and grouping of the clauses leads me to the conclusion that (f)(1)(iii) provides an acceptable alternate to a double rail system. It does not stand on its own but it modifies the preceding statements for specific conditions.

 

[JLNJ]

They deliberately included f.1.iii because the older stairs are grandfathered in and it was a way of writing into the code what had previously been a grey area. The guardrail/stairrail mess had been subject to many questions and clarifications over the years. For a long time 30" was all you needed at a stair, no matter what the fall hazard. This was illogical, so they tried to beat some sensibility into the wording by requiring at least a 36" rail at stairs. Now the 36" rail was too high to act as a handrail so they had to write in a clarification that the 36 to 38" rail could be used as both. They finally came to their senses and ditched the whole nonsense as of 01.17.2017. I don't think it's intended to be used as a loophole moving forward.

It's pretty simple. If you have a fall hazard, provide 42" guarding on walking, working, and stair surfaces. Provide a second rail to grasp on stairs.

 

[mcdermott2]

I disagree with IFRs and agree with JLNJ. I think the literal reading of this section is that, as of 1-17-17, you need to ensure the top rail is 42", and a second hand rail needs to be provided. As JLNJ noted, the (f)(1)(iii) clause is not intended as a loophole allowing lower top rails.

 

[IFRs]

JLNJ - you may be right and there is logic to your statements. But, I'm not on that committee, was not in the room and I'm not at liberty to interpret the standard this way just because I like it that way and agree with your interpretation. I can only read it as I see it. The grandfathering is clearly only f.1.ii and does not apply to f.1.iii which is another section that is part of f.1 and not f.1.ii. You might think my view is an interpretation but as a member of another standards writing committee this is how we are taught to read and write our standards. Paragraph numbering and grammar matters and is deliberately used to convey legal meaning. If they wanted f.1.iii to be included in the grandfathering then it would have been f.1.ii.C but it's not. It's just another part of f.1, independent of f.1.ii and not subject to f.1.ii

I try not to get inside the head of the writer and while f.1.iii could be read to contradict f.1 perhaps it does not - I've got no problem with it being that for stairs (not platforms or walkways) 42" is the top rail height and the hand rail is 30" to 38" but if the top rail is 36" to 38" it can also be the hand rail. Seems quite reasonable actually and the way they wrote it is about as clean as it could be.

Of course, this is only my opinion and if you have inside knowledge of the process please let us know.

 

[WinelandV]

IFR,

1910.29(f)(1)(iii)(B) says that you have to comply with all of (f), which includes the requirements for stairs built after January 17, 2017 to have a rail at 42" above the leading edge of the stair.

Of course, upon closer reading, I see that 1910.29(f)(1)(iii)(B) says that the top rail has to comply with the other handrail requirements of (f).... And thus, the OSHA req's devole into a word salad (again).

They should have just said that the geometry for a stair hand and guard rail needs to conform to IBC provisions.

 

[JStephen]

"Request for Interpretation" is being sent in today. Allow 6 months or maybe never for a response.

Item 1:
The exemption in 1910.29(f)(1)(iii)(A) and accompanying Figure D-13 allows a stair rail to serve as handrail when between 36” and 38” in height. Does this exemption apply ONLY to those handrails installed prior to January 17, 2017?

Item 2:
Section 1910.28(b)(11)(ii) references the accompanying Figure D-2 for handrail requirements. In Figure D-2, under the “Two open sides” column, a stairway 44” to 88” wide requires “One stair rail system with handrail on each open side”, while a stairway less than 44” wide requires just “One stair rail system each open side”. Does this correctly indicate that a stairway less than 44” wide with stair rail systems each side does NOT require handrails on either side?

 

[IFRs]

JStephen -

Well done!

If it is not too late, your first question uses "stair rail" when the language in the standard is "top rail".

Here is another way of saying it:
Is a single rail between 36" and 38" acceptable as a stair rail system if it meets all hand rail requirements? Reference 1910.29(f)(1)(iii) and accompanying Figure D-13.