Eng-Tips is the largest engineering community on the Internet

Intelligent Work Forums for Engineering Professionals

OSHA 29 CFR 1910 Subpart D 1910.28 Section 1910.28(b)(11)(ii) Table D-2 handrail inquiry 6

Status
Not open for further replies.

mcdermott2

Structural
Nov 3, 2015
29
0
0
US
Hello!

I understand that Table D-2 (1910.28(b)(11)(ii)) contains a printing error, and that 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". This was corroborated on the OSHA FAQ page for a while (see the attachment to this post), but that specific question and response has since been removed by OSHA.

Years ago, I reached out to OSHA and received confirmation that although that question and answer had been removed from their FAQ, that it was still valid and that OSHA intended to correct the table in a published notice (I've copied my inquiry and OSHA's response at the end of this email).

My question is, has anyone on this forum seen a published notice that corrects this error, or have any similar experiences they could share? I feel like every month I'm dealing with a platform vendor who is omitting handrails from their stair rails, where I have to go through the song and dance of explaining the OSHA printing error, and pushing them to include the handrail to meet the actual intent of the OSHA rule, and am hoping that there is some documentation out there that I'm missing where this error has been resolved.

Thanks in advance!





INQUIRY I SENT TO OSHA AND THEIR RESPONSE:
Topic & Question

Topic: Other
The OSHA FAQ previously
had the following question and response:

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).

I notice that this question/response has since been removed. Is this response still valid, and is there a rough date when OSHA is planning to correct with a published notice?
Submit Date: 08-OCT-19 04:13:29 PM

OSHA Response(s)
Hello mcdermott2,


Thank you for your correspondence to the Occupational Safety and Health Administration (OSHA) regarding OSHA?s Walking-Working Surfaces rule. You are correct that the question and answer regarding Table D-2 in OSHA?s Walking-Working Surfaces FAQs have been removed. OSHA still plans to correct the table in a published notice, but does not have a date as to when that publication will occur. For questions
regarding current OSHA enforcement policy, please contact the Office of General Industry and Agricultural Enforcement Programs within OSHA?s Directorate of Enforcement Programs at 202-693-1850. Thank you for your interest in occupational safety and health.




 
 https://files.engineering.com/getfile.aspx?folder=972d9756-33c0-48f6-9e72-6ed4f9db460b&file=OSHA_FAQ.png
Replies continue below

Recommended for you

The Vol. 86, No. 96 Federal Register post also clarifies when a top rail can serve as a handrail (another topic discussed in this thread)!

See the following for one snippet on the topic (there are others in the attachment if you want more info):

"In light of the employer confusion following the 2016 rulemaking regarding the height requirements for combination top rails, OSHA is proposing to expand the height range in the proposed paragraph (f)(1)(ii)(A) to state that the top rail of stair rail systems installed prior to the effective date of a new final rule can serve as a hand rail if that top rail is 30 to 38 inches in height, and meets the other handrail requirements of paragraph (f). OSHA is not proposing to require employers to modify otherwise compliant stair rail systems installed between Jan. 17, 2016, and the date of any final rule resulting from this proposal."

 
Status
Not open for further replies.
Back
Top