When to apply OHSA over IBC and ACSE 1

[walrus102882]

I currently work for the Facility Department of a company classified as General Industry by OHSA, prior to this I worked for a private engineering firm designing bridges. Now I'm dealing with OHSA regulations and I'm curious how other people apply them. For example, I have been asked to look at some stairs. The stairs are structurally sound but the pitch/rise and run is steeper then allowed by todays codes. The building was constructed in the 1960's and I have over a dozen of this same type of stairs. I would like to say they are "grandfathered in" but the safety department says OHSA regulations apply and must always be meet first before in other building codes. Has any one had any experience dealing with existing conditions and current OHSA codes?

Thanks for your input!

 

[CTW]

It depends on the purpose of the stairs. Are they for access between floors of an office building, or machinery, or a mezzanine, etc.? Most of the time I've felt 1910.24 was fairly clear on when OSHA applies, but in cases where I felt there was a gray area, I've always used the most restrictive code.

1910.24(a)

"Application of requirements." This section contains specifications for the safe design and construction of fixed general industrial stairs. This classification includes interior and exterior stairs around machinery, tanks, and other equipment, and stairs leading to or from floors, platforms, or pits. This section does not apply to stairs used for fire exit purposes, to construction operations to private residences, or to articulated stairs, such as may be installed on floating roof tanks or on dock facilities, the angle of which changes with the rise and fall of the base support.

 

[SlideRuleEra]

I currently work for... a company classified as General Industry by OHSA...the safety department says OHSA regulations apply and must always be meet first before in other building codes.

OSHA has been around long enough (about 45 years) for a fair amount of flexibility to be incorporated into the enforcement of standards. Use the web to look for details of regulations.

See if your "general industrial" stairs meet the requirements of paragraph 1910.24(e):

Fixed stairs shall be installed at angles to the horizontal of between 30 deg. and 50 deg. Any uniform combination of rise/tread dimensions may be used that will result in a stairway at an angle to the horizontal within the permissible range.

Here is the link to that section:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9716

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[Ron]

If the stairs are used primarily for industrial access by employees of the company and not the general public, I would yield toward OSHA. An OSHA citation is much more onerous than a building code interpretation issue.

 

[walrus102882]

Thanks for the quick responses. These stairs are mainly for employees to enter the building. I have attached a pic for an example. We have had two workers trip recently due to the steepness, which is why this stairs are all of a sudden an issue. The run is just over 6 inches and the rise is about 7 in must places.

Thanks Again

 

[BadgerPE]

I don't know that OSHA would govern in this situation because it is an egress pathway, which is governed by IBC or your local building code.

 

[JStephen]

OSHA gives minimum requirements for stairways. It doesn't mandate that you only use the minimum requirements.
Where a new building/stair is covered by a building code, it would generally fall under that building code, but that, in most cases, would meet OSHA as well.
If a building is accessed by the public, it would make sense to conform to the building codes whether required or not.
A lot of industrial facilities aren't covered by any building code, and in that case, OSHA would still be the minimum requirement.
If it looks like the stairs are a problem, consider updating them, even if not required. Warning signs might help.

 

[walrus102882]

Thanks for all the input. The safety guys love to find random codes and say we need this or that. Thanks for clearing some things up.

 

[dhengr]

Walrus102882:
7" is about right for the rise, but 6" is mighty small for a tread (the run), doubly so when you have a solid riser, as on those conc. stairs. I believe the run should normally be a min. of 11". This would not likely pass muster for the IBC, particularly since it is an ingress and egress stairs to a building. As Jstephen suggests, I’d consider changing those stairs. I law suit or claim will cost you more than the new stairs. And, as is the case with many companies these days, you are probably harping more and more about safety, so the worker are all the more aware of these issues. They just don’t pay any attention to what they are doing, until after they get hurt. The most important thing is that the run and the rise be consistent as the users develop a cadence in using the stair. Any variations is this run/rise ration in the stair run is the real tripping hazard on stairs and ladders and the like. When the rise gets larger than the run, I think this starts to boarder on a ship’s ladder, which OSHA allows in some conditions, but not as a bldg. entry stairs.

 

[racookpe1978]

But in this case, you've already had "two strikes" - two trips.
Regardless of whether you can "excuse" these particular stairs - NOT "all in the building" stairs! - these particular ones need to be changed. And can be relatively simply because they are straight "out" fro the building, end up in an existing "reserved" exit space, and cane be built over with new concrete very cheaply.

Cheaply, compared to a further trip in the same place when ice or snow is on the "too short" treads.

 

[Jerehmy]

A lot of older buildings don't meet todays codes. Doesn't mean you have to upgrade your building everytime a new code comes out. Whoever owns these stairs is not obligated to upgrade these stairs.

As long as they followed all the standards at the time the stairs were built I don't see how they could be sued either.

If you're renovating a portion of the building you may be obligated to upgrade these stairs depending on what percentage of the building is being renovated.

But if they're throwing money to fix this specific set of stairs, then they might be obligated to have to fix all the stairs in the building. Otherwise they could probably get sued because they acknowledged the stairs were a problem.

 

[thaidavid40]

If this stairway is for personnel access, then it is classified as an egress stairway, and its characteristics are governed by the IBC, and by NFPA 101, the Life Safety Code. If it is a fixed industrial stair, i.e.: for maintenance access, equipment access, catwalk access, platform access, roof maintenance access (uninhabited roof), etc., then it is governed by OSHA requirements.

Thaidavid

 

[IFRs]

Your first responsibility as a Professional Engineer is for the public safety. Since you already have at least two documented cases of trips and/or falls, I would get rid of them. You have been warned! Why ignore all the signs??? Not only does it protect the public but it will reduce your company's liability. The next one could be a pregnant lady and a huge lawsuit for ignoring documented non-code hazards. By the way, what the heck happens in the winter???

 

[SlideRuleEra]

Walrus102882 - Step back and take a look at this situation a little differently. You tell us that you are employed by this company. I assume the people who have been injured are your coworkers. I would expect that the safety department and the facilities department are not adversaries. You no longer have "clients" is the sense that you represent one side of this issue, as you may have at your previous employer. Your clients are your coworkers. Others have pointed out that the stairs in the photo do meet the intent of either OSHA or building codes. They have been proven unsafe.

IMHO, quit trying to find a technical or administrative "loophole" to keep the stairs. Do what is best for your company - replace the stairs.

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[DBronson]

Walrus102882:

The IBC (or the variant of it adopted by your locality) essentially applies to all stairs in commercial buildings. Whether it's a required means of egress or not is irrelevant. Legally the company has to comply with OSHA and the Building Code. For an existing building you can use either chapter 34 of the IBC or the IEBC - it depends on which code your local area has adopted. The existing building codes are more forgiving than the codes for new buildings. As mentioned above you don't need to upgrade a building to current code unless there is a major remodeling being done. An additional thing you should be aware of is the accessibility code ANSI A 117.1 (aka the ADA). The stair pictured doesn't begin to comply with that.

Slide rule has nicely summed it up - that's the best (and probably the cheapest) solution, all things considered.

Regards,

DB

 

[walrus102882]

Thanks for all the advice.

To clarify, these stairs are just one example of the type of items that come across my desk. I agree completely with everyone that brought up the safety issue. In this particular situation, regardless of code, the stairs have already proven to be a safety issue and I have closed access to the building using those stairs.

I wasn't looking for a loophole or technically to keep the stairs open, like IFRs stated, are first responsibility is to public safety. I was just trying to gain a better understanding of what other engineers do in situations where someone is quoting an OHSA regulation and insisting a new set of stairs, ladder, platform ect.; yet all other codes are meet or were meet at the time of construction.

Thanks again everyone.

 

[Jerehmy]

I wasn't giving a loophole, I was just telling you how it is. Calling it a loophole makes it seem shady.

Remodeling isn't cheap and when you do it you may have to upgrade other things that weren't on your radar. Maybe the company couldn't afford a complete upgrade of the stairs for a bit. At keast they know they aren't under any legal obligation and could do it when they get the time/money.

And are they egress stairs? I don't know if I would restrict accces in case of fire, etc.

 

[TXStructural]

I was in a conference address this week wherein the head of OSHA emphasized that compliance with OSHA regulations make a workplace safer but not safe. Equally, the building codes (specifically IBC) are minimum code for life safety. Having worked as both a facility safety engineer and a structural engineer, I have been on both sides of this kind of situation. In both roles, the struggle is to find solutions that comply AND provide the owner/employer with best value.

In the OP's situation, OSHA requirements are for current conditions without regard to preexistence or cost. OSHA applies to any part of the premises and property where employees are during a workday, including getting into the workplace. And the most important issue with OSHA is that the general duty requirement is to provide a workplace free from recognized hazards. That said, having a couple of people stumble on stairs when entering the building, I would not presume that the stairs are a problem UNLESS they also do not comply with stair construction requirements in OSHA or IBC. If the stairs are substandard, then the presumption is that they are a hazard and reports from employees of stumbling confirms that.

I would chalk this up to a construction oversight (or an afterthought) and have them redone. It looks to me like the stairs may have been previously replaced to add the ramp and improve the landing, while keeping the steps within the same footprint, resulting in steep stairs.

 

[racookpe1978]

It's a front entrance - right next to the "Reserved Parking" for the Director and Visiting VP's.

Does it make sense commercially to blockade the first thing a visiting VP and your director see when they park in front of the building every morning, noon, and when they leave by a different door inside that night?

Yes, there may be other stairs affected, and this will cost (a little bit!) of money to fix. But less than the price of a new sign at the front gate.

 

[JLNJ]

How old is the building? I would guess that the stair run did not meet the building code requirement of the day.

Short treads are very dangerous. Replacing them is not all that expensive.