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

 

[Bagman2524]

I'm with IFR and Carl B on this one. Pretty clear to me that section 1910.29(f)(1)(iii) as shown in Figure D-13 allows a single stair-rail 36"-38" above the nosing line, when the top rail is also used as a handrail. (This is not a grandfather clause - it is an exception to 1910.29(f)(1)(ii)(B) that applies to all future cases).

If the top rail is not used as a handrail, then the stair-rail needs to be 42" above the nosing line per 1910.29(f)(1)(ii)(B).

The exception is similar to NFPA-101 which allows the top rail of a guard at 42" high on side of a stair to also be used as a handrail. Otherwise the handrail is required to be between 34"-38" high.



All I know is P/A and Mc/I

 

[WinelandV]

Alright, did some digging on the Final Rule to Update General Industry Walking-Working Surfaces and Fall Protection Standards.

Pertinent Links:
Link 1
Link 2
Link 3

That last link is to the federal register of the walking surfaces rule, and is most important as it goes into great detail explaining what they are/were intending to do when the updated the rule. From Section IV: Summary and Explanation of the Final Rule:

Second, because the final rule requires that all stair rail systems installed on or after the effective date, which is January 17, 2017, must be at least 42 inches in height, final paragraph (f)(1)(iii)(A) is only applicable to stair rail systems installed before the effective date. Third, OSHA adds to the final rule the requirement that employers may use stair rails as handrails only if the stair rails also meet the other requirements in paragraph (f). NFPA recommended that OSHA allow the use of stair rails as handrails only if they also meet the handhold requirements in proposed paragraph (f)(5). NFPA recommended an addition to the proposed provision, stating:

[The addition] recognize the stair rail as an acceptable handrail not only based on height but if it additionally provides the handhold required of a handrail. The user would not otherwise know that the stair rail needs graspability as the provision of 1910.29(f)(5) is written to have applicability to handrails, not specifically to stair rails that are at an appropriate height so as to serve as a handrail (Ex. 97).

(italics added by me)

Link to this specific section here. Note that this appears to clip out the area of the rule discussion. Use Link 3 for access to the entire document.

 

[Bagman2524]

Following up on the 3rd link winelandv's post, I've changed my position. I pdf'd the 3rd link and winelandv's quote is on page 137 of 513 pages. I reduced the applicable discussion to 3 pdf pages (attached).

Section 1910.29(f)(1)(iii) does appear to be a grandfather clause that only applies to rails installed before Jan. 17, 2017.

My concerns are:

Why has OSHA written (f)(1)(iii) so that it appears to be an exception to (f)(1)(ii)(B)? Why haven't they clearly stated in the section that it only applies to rails installed prior to 1/17/17? Do they really expect people to research a hard to find 513 page Final Rule to obtain this information?

Why hasn't OSHA added another line that allows the top rail of a 42" high stair-rail to also be used as a handrail for rails installed after 1/17/17? They have completely omitted this possibility, which is in NFPA-101, and which is what most of 1910.29(f)is based on.

All I know is P/A and Mc/I

 

[IFRs]

Well, now I'm confused. The commentary says they wanted iii to fall under the limitations of ii but the final rule did not include it in ii (typo or did they change their minds?). The pdf posted also includes commentary that says a 42" top rail can be a hand rail if it meets other hand rail requirements. But this is not in the final standard - instead iii says a 36-38 top rail can also be a hand rail, and shows this in figure D-13 just to make it clear.

Is there any case where an OSHA top rail can be a hand rail after Jan 17, 2017 ?

 

[Bagman2524]

I submitted the following question to OSHA:
29CFR section
1910.29(f)(1)(iii) allows the top of a stair rail system to serve as a handrail if the height is 36"-38" above the leading edge of the stair treads. Is this section an exception to 1910.29(f)(1)(ii)(B) which requires the height of stair rail systems installed on or after January 17, 2017 to be 42" minimum above the leading edge of the stair treads? Or does 1910.29(f)(1)(iii) only apply to stair rails in place prior to January 17, 2017? And if 1910.29(f)(1)(iii) only applies to stair rails in place prior to January 17, 2017, Is there a section that allows for the top rail of a stair rail system to also serve as a handrail, for rails installed after January 17, 2017?

This was the reply from OSHA:
The 36-38 inch standard only applies with a grandfathered stair rail. OSHA plans to issue a clarification.

In general grandfathering provisions usually only apply to existing conditions; modifications to existing structures would typically conform to current standards.


All I know is P/A and Mc/I

 

[IFRs]

Bagman2524 - can you post the OSHA interpretation so I have some backup?

Now that we are done with the rail system, what are the rise and run requirements for a spiral or winding stair around the outside of an API storage tank? I recently was forced to use 7" rise maximum and 11" run minimum and have 5 more to do for other clients.

 

[mcdermott2]

Hi, All,

One item that a colleague brought to my attention that might be useful to you all:

A stair rail does not necessarily require a handrail. Table D-2 under section 1910.28(b)(11)(ii) provides handrail requirements. If you have a stair open on two sides with a stair width less than 44 inches, it appears as if no handrail is required, just a stair rail (top rail, mid rail toe plate).

If the stair is to be enclosed, or has one open side, then you do need a handrail, and as I indicated in my original post, I interpret the code to indicate that the top rail can no longer serve as the hand rail.

 

[JLNJ]

That doesn't make any sense. The whole point of the rule is to have a guard at 42" and the recognition that you need an additional handrail because a 42" guard is too tall to grasp as a handrail.

Look at Table D-2 Stairway Handrail Requirements. If specifically indicates that you need a guardrail (they maddeningly call it a "stair rail system") with handrail on both open sides.

 

[mcdermott2]

Thanks, JLNJ,

For a two open side stairway with less than 44 inch stair width Table D-2 requires "One stair rail system each open side".

For a two open side stairway with greater than 44 inch stair width Table D-2 requires "One stair rail system with handrail on each open side".

I read "One stair rail system each open side" and "One stair rail system with handrail on each open side" as different things. I read the former (One stair rail system each open side) to exclude requirement for a handrail. I read the latter (One stair rail system with handrail on each open side) to require a handrail.

That is about as clear as I think I can write it - Please help me understand what doesn't make sense, seems black and white to me.

As such, the additional hand rail requirement discussed earlier in this thread applies to situations where D-2 indicates that there is a requirement for handrail (like a stair that has two open sides and a stair width greater than 44 inches).

 

[JLNJ]

As from the outset of this thread, I still think you are trying to find an "out" which isn't there and isn't logical.

When I read "closed" I think "with walls, like in a hallway". In this specific case, if the hallway is narrow enough, you need just one rail.

If it's "open" you need a guardrail and a handrail. If one side is "open" and one side has a wall (and it's under the 44" width), then the non-wall "open" side gets the guard and the handrail. If it's wider, you need a handrail on the walled side as well as well as the the guard and handrail on the "open" side.

The whole point of the table is to:
- allow a single handrail if the stair is narrow and the sides are enclosed,
- require guards and rails on open sides, and
- require an additional handrail down the middle of extra-wide stairs.

For a two open side stair with width less than 44 inches Table D-2 requires "One stair rail system with handrail on each open side." You omitted the with handrail in your above post.

 

[Bagman2524]

I read Table D-2 the same as JLNJ. Including "Enclosed" being with a wall on each side. Except JLNJ is incorrect on Table D-2 wording for stairs with two open sides and less than 44" wide. The table only states "One stair rail system each open side. It doesn't mention handrails.

Here Table D-2 also has a glitch in it (which was picked up by McDermott2 above). For Stairs less than 44" wide and having two open sides, Table D-2 only states that One stair-rail system is required on each open side. It seems to imply but doesn't state that one handrail is required (but not one on each side), which is stated for "Enclosed" stairs or stairs with "one open side".


IFRs - Attached is my question to OSHA concerning stair-rail height (pre & post Jan 17, 2017).


All I know is P/A and Mc/I

 

[JLNJ]

Interesting catch on Table D-2 and my apologies to @mcdermott2 if I have it wrong.

I have an 88-page PDF on my desktop of the "final rule" which has the with handrail included (see the snip attached)

Maybe my copy isn't "official" but it's right from the OSHA website's "Regulatory Text".

 

[mcdermott2]

Thanks for the summary, Bagman2524 (and thanks for the snippet including response from OSHA). I agree with your interpretation of "enclosed" but regarding "open" sided stairs I disagree that Table D-2 implies the need for one hand rail on one side for a stair with width less than 44" (I just don't see any explicit mention of this in the OSHA provisions). Based on the online version of 1910.28 Table D-2, I do not believe that a handrail is required for an open stair with width <44".

JLNJ, thanks for the snippet showing the D-2 Table that you were referring to. The D-2 table I am referencing is from the following URL:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9720.

If your resource is correct, and the online version is wrong, then that is certainly something that should be cleared up by OSHA (perhaps you could take the honors of submitting a query to OSHA noting the discrepancy).


One nit to pick:

As from the outset of this thread, I still think you are trying to find an "out" which isn't there and isn't logical.

I think the following quotes from this thread refute this statement:

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

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.

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!

My initial stance was that, yes, I needed an additional hand rail now that the top rail requirement has changed. With the review of Table D-2, I have clarified my stance to only apply to those locations where Table D-2 indicates that a handrail is required.

This is a minor point, but I don't like to be mischaracterized (hence the now picked nit).

Thanks all for the great discussion so far. I think an important aspect of this thread is the communication with OSHA indicating the need for clarification on the topic.

 

[Bagman2524]

OSHA has a disconnect between their "Final Rules" and the actual regulations in 29CFR1910.

I.e.

Final Rules state the 36"-38" stair-rail/handrail combination applies only prior to Jan. 17, 2017. 29CFR1910.29(f) doesn't specifically state that the 36"/38" stair-rail/handrail combination only applies prior to Jan. 17, 2017. The way the 1910.29(f) is worded seems to imply that the 36"/38 stair-rail/handrail combination is an acceptable alternative to the 42" stair-rail.

Final Rules Table D-2 shows stairs less than 44" wide with two open sides needing stair rail system on each open side and a handrail on each side. 1910.28 Table D-2 shows that a stair rail system is needed on each open side. There is no mention of handrail requirements.

All I know is P/A and Mc/I

 

[IFRs]

Given this disconnect, which are we legally obligated to follow?

 

[SandCounter]

Could 1910.29(f)(1)(i) refer to the closest distance from the nose of the step to the handrail (perpendicular) and 1910.29(f)(1)(ii)(B) refer to a vertical distance from the nose of the step through the hand rail? Sketch attached.



I used to count sand. Now I don't count at all.

 

[Bagman2524]

No, I don't think so. I've never seen handrail height measured that way in any of the building codes (i.e. IBC, NFPA-101, etc.). Handrail Height is always measured vertically.

My understanding is that 29CFR is law, while Final Rules are commentary.

All I know is P/A and Mc/I

 

[BamaStrucPESE]

Interested to see if OSHA has replied to anyone yet. I am having this same discussion with a vendor.

 

[JStephen]

No word here. But then, it's only been 3-1/2 months, and this IS the federal government.

 

[D_A_N]

JStephen any word? Almost 6 months.