OHSA stair guard height requirements 2

[Bagman2524]

OSHA section 1910.23(e)(2) requires Stair Rail heights to be 30"-34" high. How does one design/build a stair with the required guard heights of 42" and handrail heights of 34"-38" per NFPA-101 and IBC; and still meet the OSHA Stair Rail height requirement/range. Would a stair with 42" guards and an interior handrail at 34"-38" still meet the OSHA requirement? Does the guard being over 34" violate this OSHA section? Would the handrail have to be exactly 34"?

Note that OSHA uses the terms "Handrails", "Stair Rails" & "Standard Rails". While IBC and NFPA-101 use the terms "Guard" and "Handrail".
Handrail in OSHA is equivalent to Handrail in IBC/NFPA.
Stair Rail in OSHA is equivalent to a combined guard and handrail in IBC/NFPA.
Standard Rail in OSHA is equivalent to a guard for a platform or other flat surface in IBC/NFPA, (but not a guard alongside a stair).

Also note that OSHA has a Standard Interpretation and Proposed Rule 1910.28(c)(2)(ii & iv) to allow stair rails to be up to 36"-37" high, but 1910.28 only applies to scaffolding.

 

[fegenbush]

"How does one design/build a stair with the required guard heights of 42" and handrail heights of 34"-38" per NFPA-101 and IBC; and still meet the OSHA Stair Rail height requirement/range?"

Please see the attached image. If both OSHA and building codes must be met, it is often necessary to do separate the requirements to satisfy them both.

 

[Once20036]

Typically for stairs in industrial areas, we have the handrail and no guardrail.
We've never had any issues with this for non-egress, non-publically accessible spaces.

 

[JLNJ]

If it falls under the jurisdiction of the Building Official then it will need to comply with the IBC. You'll need both the 42" guard (with intermediate rails as prescribed) and an additional "hand"rail for grasping down at 34".

I have had a disagreement with a building official who wanted to required a full egress stair in a location that should have been an OSHA stair. My way of looking at it is that if you would be permitted to place a ladder instead of a stair, then it should be an OSHA stair. If a stair is building code required due to occupancy, then you will need a 7"/11" stair with all the trimmings (no open risers, handrail graspability and extensions, minimum width, cover (if exterior) etc). OSHA stairs can be much more steep (and narrow) and are generally more flexible in their design.

 

[IFRs]

Aren't fixed industrial stair railings now 36" ?

 

[CTW]

Not according to OSHA. But I thought I saw the 36" requirement somewhere too.

1910.23(e)(2)

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.

 

[Bagman2524]

There is a proposal on the books to increase the height of a stair railing to 36", but the proposed change is to 1910.28 which is for scaffolding.