OSHA Legal? Intermediate Stair Landing Above Vessel

[FoxSE14]

I'm reviewing a design in which a colleague of mine placed a small intermediate landing for a fixed stair such that the walking surface is approximately 3'-0" directly above a vessel (industrial facility). The landing area is more-or-less centered over the vessel, we have provided the necessary clearance for piping, and landing/stairway/railing/toeplate geometry is legal per OSHA.

The question has been raised by others: "is the proximity of the landing to the vessel legal per OSHA?", their concern seems to be - "what if there's a leak/rupture of the vessel/piping that renders the landing/entire stair useless in an emergency?" I cannot seem to find any direction from OSHA. At 6:30pm on Friday - I don't know yet what the contents of this vessel are. Does it matter? What if the walking surface were 2'-0" above the vessel?

I'm leaning toward "it's legal" because I don't see how this is any different than the similar leak/rupture hazards presented by piping running beneath a 3'-0" wide catwalk - see this all the time. The difficulty is that, if 'illegal', it appears we do not have many other options for the location of this stair, (inside an existing building). (We have a fixed ladder provided for alternate means of egress from all levels as well).

Any comments/guidance/cautionary tales would be appreciated! Happy weekending.

 

[Duwe6]

Assuming vessel is 'tight' and not open to atmosphere
assuming the vessel is protected with a correctly sized PRV
assuming said PRV is vented well away from the platform & stairs

of course it is safe.

If condition #2 is not met, flee the building
If condition #3 is not met, 'red tag' the stairs & platform.

 

[MJCronin]

My understanding of OSHA mandate is to ensure safely constructed and adequately sized stairways, walkways etc.

Where the stairs and walkways are placed and the proximity to all kinds of dangerous equipment and components should be reviewed during a HAZOP/Plant safety analysis of the process.

OSHA does not regulate proximate process dangers in the guidelines developed for stairs, landings and walkways.

 

[toone]

You are asking is it legal? That sounds like a question for lawyers. Maybe you should be asking is it safe? There are many details to consider to determine the safety of this platform and the best thing you could do is to invite an OSHA compliance officer to your facility for guidance. When invited to a facility by an employer compliance officers do no write citations (unless safety hazards are observed and not abated).

Things to consider when assessing the safety of the platform include, the structural integrity of the platform, hand railing, contents of the vessel, open or closed vessel, pressure of vessel, location of pressure relief devices. An OSHA compliance officer can help ensure that the platform is safe. That is his job and that is why he is taking your tax dollars. Put him to work doing something more useful than writing tickets.