OSHA handrail or guardrail?? 3

I can't help with the interpretation, but if the client prefers you interpret it as the more conservative option (handrail), why not give him what he wants?

Have you contacted OSHA directly or reviewed their selection of letters of interpretation?

Often, the question at hand has come up before, and OSHA has provided an official position.

In my work, I deal with temporary guardrails frequently and the term is used for construction purposes, not permaanent use.

It feels like your situation warrants a proper hand rail for the stair, but I cannot cite a code reference to push that.

Good luck!

Daniel

Landings do not require handrails, only guardrails. Handrails are only required where the elevation is changing, such as a stair or a ramp.

Bagman2524's right on this one. The definitions he gives are literal in this context. A guardrail is something that stops you from falling off of an edge, a handrail is something you use to steady yourself while climbing/descending and require adequate hand clearances.

Bagman and Swearingen may be technically correct, but if the client wants this railing designed as a handrail, what's the problem? He's the one who is paying the bills and he is the one who will have to live with it. Give the client what he wants.

bagman and Swearingen thanks so much, you are 100% correct but its hard to come up with an actual OSHA code paragraph other than interpretation letter re: 1910.23e6 from 1995.

I think we cant cow tow to clients and do something that is not required, we are being reimbursed by them for our knowledge and if anything we should be "educating" them rather than doing unecessary and time consuming changes.

rfied112 said, I think we cant cow tow to clients and do something that is not required, we are being reimbursed by them for our knowledge and if anything we should be "educating" them rather than doing unecessary and time consuming changes.

Wow.

I agree, always give the client what he/she wants, whether its' necessary or not. (assuming our course it doesn't violate a code or create a hazardous condition.)

Most building codes differentiate between a guard and a handrail as swearingen discussed above. Also note that a guard doesn't have to be a rail. It can be anything (wall, ornamental pattern, etc). that prevents a person falling off the level they're on to an adjacent lower level. Most codes require guards where there is a drop off more than 30 inches. (4 ft under OHSA 1910.23e(1))

OHSA 1910.21 however uses the terms standard railing, stair railing and a handrail.
A standard railing is basically a guard.
A stair railing is basically a guard on the sides of a stair, that can also act as a handrail.
A handrail is a rail mounted to a wall to furnish people a handhold to prevent tripping and falling down the stair.

So going back to rfied112's orginal question. A standard railing is required around the platform, and it falls under OHSA 1910.23, Guarding floor and wall openings and holes. I'd like to know where your client is coming up with 1.5" clearance for handrail. 1910.23e(6) requires 3" clearance for handrails and railings. It looks to me like this could be interpreted to apply to standard railings and stair railings as well as handrails.

bagman: Under OSHA 1910.23 e 6 Interpretations in osha.gov is a letter from 1995 where OSHA states that ANSI A.12 is the source of their requirements and since ANSI changed from 3 inches clear to 1.5 inches clear and also changed to clearance just for "stair" type railing OSHA was changing to match ANSI and had published in the federal register as such (68:23568).

note that IBC 2003 is also 1.5 inches clear for handrail

Thanks rfied112. I was unaware of this change.

If you are less than 44" wide the handrail on the inside of the stringers may suffice and the exterior rail won't matter.

Check (your local) Building Code requirements carefully: I work part-time in ornamental iron railings and stair handrails, and this kind of confusion and differences come up with ADA as well.

Commercial (all business-accessible areas used by the general public) buildings, around a raised platform more than 30" up, require a 42" high guardrail whose sides meet the 4" maximum opening rule AND a separate (for stairs and ramps) handrail 36" (+/- 2") high. That 36" is measured at the nose of the treads. A business ADA-compliant handrail should extend horizontally 12" more at the top, measured from the nose of the upper tread. At the bottom, extend the handrail down one more stair tread (so the handrail projects onto the floor), then go the 12" flat. Commercial building handrails should return (under or into the wall), and not just terminate in mid-air.

ADA-ramps more than 15" total rise need the ADA-handrail as well: but check that 15" max rise.

Homes don't the 42" high guardrail, and most of the time the house combines the top of its guardrail at 36" (+/-2") with the handrail requirement- also 36" from the floor. Homes don't need the 12" extensions either. All handrails (home & business) should have 1-1/2" clear from the wall or any projecting knuckle-knocker.

But this is for a commercial maintenance (non-access to general customers!) tower in a county I"m not familar with. That limited access (or professional worker only) access throws normal Buildig Code rules out the window. OSHA, on raised working platforms, requires a toe guard as well.

Sorry, I can't reliably guess about the handrail/guardrail quandry for your particular case for a tower. Robert

heres the OSHA Interpretation:


U.S. Department of Labor
Occupational Safety & Health Administration
MyOSHA [skip navigational links] Search Advanced Search | A-Z Index

Standard Interpretations
05/26/1995 - Handrail and railing clearance for runways (hangar catwalks).

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Standard Interpretations - Table of Contents
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• Standard Number: 1910.23(e)(6)

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OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

May 26, 1995

Mr. Scott Stratton
Vice President
Stratton, Inc.
2513 Deaton Street
Lake Charles, LA 70601

Dear Mr. Stratton:

This is in response to your September 8, 1994 letter requesting interpretation of the Walking-Working Surfaces Standard, 29 CFR 1910 Subpart D, as it may apply to the catwalks described in the workplace scenario below. Your questions and our reply follow. Please accept our apology for the delay in responding.

Scenario: An aircraft maintenance hanger has catwalks at approximately 38 feet (11.58m) and 58 feet (17.68 m) above the floor below. The lighting for the hangar which is suspended from the catwalk guard/handrails is well grounded and meets the National Electrical Code. The rails consist of 2 inches (5.08 cm) by 3 inches (7.62 cm) angle at the top and intermediate rails. The mounting bracket for each of the lighting fixture is attached directly to the top rail of the catwalk as depicted on the sketches: Detail l-El7 and Detail l-El9, enclosed with my letter.

Question 1: Does paragraph 1910.23(e)(6) apply to the catwalk described in the preceding scenario?

Question 2: Does this mounting method violate paragraph 1910.23(e)(6) which requires a clearance of not less than 3 inches (7.62 cm) between the handrail or railing and any other object?

Question 3: Are other brackets for catwalk lighting per sketches: Detail l-El7 and Detail l-El9 or the typical motorized (air, lighting, and receptacle) cable mounting reel per the sketch titled: Detail l-El5) subject to this paragraph 1910.23(e)(6) clearance requirement.

Reply: The catwalks described in the scenario above are considered runways as defined under existing paragraph 1910.21(a)(5). Runways are covered under existing paragraph 1910.23(c)(2). Under existing paragraph 1910.23(c)(2), elevated runways must be guarded by a standard railing. This requirement is intended to protect an employee using a runway from falling from an otherwise unguarded, elevated edge.

Standard railing requirements are covered under existing paragraph 1910.23(e)(1). Under existing paragraph 1910.23(e)(6), handrails and railings must be provided with a clearance of not less than 3 inches (7.6 cm) between the top railing and any other object. The source of these and other existing section 1910.23 requirements on guarding floors and wall openings and holes is the American National Standards Institute standard, ANSI A12.1-1967, Safety Requirements for Floor and Wall Openings, Railings and Toeboards. Paragraph 7.6 of ANSI A12.1-1967, which corresponds with existing paragraph 1910.23(e)(6), requires that all handrails and railings be provided with a clearance of not less than 3 inches (7.6 cm) between the handrail or railing and any other object.

In the subsequent 1973 revision of ANSI A12.1-1967, paragraph 7.6 was reworded by adding the adjective "stairs" in front of railing to identify specifically the type of railing to which the clearance requirement applied. Also, the clearance requirement was changed from 3 inches to one and one-half inches (3.8 cm). In preparing the proposed revision of 29 CFR 1910, Subpart D-Walking and Working Surfaces, the Occupational Safety and Health Administration (OSHA) reviewed the pertinent ANSI standards and determined that it was appropriate to limit the clearance requirement for handrails and stair rails. Also, OSHA determined that it was appropriate to adopt the one and one-half clearance required most recently in section 5.9 of ANSI standard A1264.1-1989. Accordingly, proposed paragraph 1910.28(c)(3), published in the Federal Register, Volume 55, Number 69 on Tuesday, April 10,1990, requires that the minimum finger clearance between handrails, including the top edge of stair rail systems serving as handrails, and any obstructions shall be one and one-half inches.

The first paragraph of the middle column of page 13375 of the preamble to the aforementioned proposed rulemaking (a copy of which is enclosed for your use) notes that proposed paragraph 1910.28(c)(3) "is consistent with the requirements of many local building codes, ANSI A12.1-1973,...."

In summary, the aforementioned proposed rule sets one and one-half clearance for handrails including the top edge of stair rail systems serving as handrails but it does not set clearance requirements for the top rail of a guardrail system. Please be advised that employer compliance with a proposed rule, in lieu of compliance with an existing rule, is considered a "de minimis violation," that is, a violation of an existing OSHA standard which has no direct or immediate relationship to safety or health. Such violations of the OSHA standards result in no citation, no penalty, and no required abatement.

Compliance with other OSHA safety standards which may apply must be determined for the particular workplace application. For example, existing paragraph 1910.23(c)(2) requires toeboards which meet existing paragraph 1910.23(e)(4) requirements wherever tools, machine parts, or materials are likely to be used on the runway such that they could fall, thereby potentially exposing employees to injury when working on the floor below.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact [the Office of General Industry Enforcement at 202 693-1850].

Sincerely,


John B. Miles, Jr., Director
[Directorate of Enforcement Programs]

[Corrected 4/4/2005.

Note: On April 10, 1990 OSHA published proposed revisions to Walking and Working Surfaces; Personal Protective Equipment (Fall Protection Systems); Notices of Proposed Rulemaking; Slips; Falls; Trips in Federal Register 55:13360-13441. It is available electronically only as an abstract. On May 2, 2003 OSHA reopened the rulemaking record on the proposed revisions to Walking and Working Surfaces and Personal Protective Equipment (Fall Protection Systems). It was re-published in its entirety in Federal Register 68:23527-23568 and is available electronically.]



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