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]

Not a peep.

 

[StrucPEng]

So after reading this thread I looked into the requirement further, as I am working on a stair right now (we do mostly industrial stairs with 2 sides open and a top and mid rail system for a guardrail). Having seen the "speedy" response from OSHA I made a call to the the state level body MiOSHA (Michigan) as they have adopted the same 1910.29 criteria. After bumping me up the chain for a few days I received the answer paraphrased as follows:

- 1910.29(f)(1)(iii)(A) is applicable to existing stair sets that require modification or replacement in kind.
- All new stairs need to follow 1910.29(f)(1)(ii)(B) as of January 2017 and the 42" stair rail with mid rail does not require an additional handrail at the 30-38" height along the open side guard rails. with that said, a stair with only one open side and a wall will still require a handrail at appropriate height on the wall side per 1910.29.

They then went on to say that their office has also received numerous calls for interpretations and they themselves have kicked it up to the federal government who have yet to provide a definitive interpretation of the clauses.

Take this all with a grain of salt as it is not an "official" interpretation of the criteria but I figured I would share what answers I have come across so far.

 

[Bagman2524]

I agree that the MiOSHA opinion (i.e. the 42" stair rail with mid rail does not require an additional handrail at the 30-38" height along the open side guard rails) is the way the regulation should be, but it's unclear from the current working in OSHA that this is correct. Until a revision or clarification is issued from the Federal Office, I don't feel comfortable using the MiOSHA opinion. A stair built without the handrail would basically be at the mercy of the individual OSHA inspector.

All I know is P/A and Mc/I

 

[IFRs]

I've made maybe a dozen industrial spiral stairways for large aboveground cylindrical tanks with one and two open sides since this thread started for a variety of clients. I've made them all with 42" top rail, 36" hand rail and 21" mid rail. Everyone of my clients take my word for it that the hand rails are required to meet OSHA but they would all be happy to not have to do it. As would I - they are a royal PITA and I'm just starting to get proficient at them.

 

[mcdermott2]

Take a look at the following OSHA FAQ:

https://www.osha.gov/walking-working-surfaces/faq.html

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).