handrail requirements per latest OSHA standard
handrail requirements per latest OSHA standard
(OP)
I have a question regarding handrails on platforms per the latest OSHA requirements. Typically I have been designing the top rail of a stair rail system to serve as both a top rail and handrail. As of January 17, 2017, per OSHA, it appears as if the top rail of a stair rail must be >= 42” from leading edge of a stair, while the height of a handrail must be 30” <= x <=38”. If this is correct, it seems to me that for a stair rail system I would need a top rail, mid rail, toe board, and now an additional hand rail. Below are the pertinent sections from OSHA. Do you all agree with this interpretation?
1910.29(f)(1)(i)
Handrails are not less than 30 inches (76 cm) and not more than 38 inches (97 cm), as measured from the leading edge of the stair tread to the top surface of the handrail (see Figure D-12 of this section).
1910.29(f)(1)(ii)
The height of stair rail systems meets the following:
1910.29(f)(1)(ii)(A)
The height of stair rail systems installed before January 17, 2017 is not less than 30 inches (76 cm) from the leading edge of the stair tread to the top surface of the top rail; and
1910.29(f)(1)(ii)(B)
The height of stair rail systems installed on or after January 17, 2017 is not less than 42 inches (107 cm) from the leading edge of the stair tread to the top surface of the top rail.
1910.29(f)(1)(iii)
The top rail of a stair rail system may serve as a handrail only when:
1910.29(f)(1)(iii)(A)
The height of the stair rail system is not less than 36 inches (91 cm) and not more than 38 inches (97 cm) as measured at the leading edge of the stair tread to the top surface of the top rail (see Figure D-13 of this section); and
1910.29(f)(1)(i)
Handrails are not less than 30 inches (76 cm) and not more than 38 inches (97 cm), as measured from the leading edge of the stair tread to the top surface of the handrail (see Figure D-12 of this section).
1910.29(f)(1)(ii)
The height of stair rail systems meets the following:
1910.29(f)(1)(ii)(A)
The height of stair rail systems installed before January 17, 2017 is not less than 30 inches (76 cm) from the leading edge of the stair tread to the top surface of the top rail; and
1910.29(f)(1)(ii)(B)
The height of stair rail systems installed on or after January 17, 2017 is not less than 42 inches (107 cm) from the leading edge of the stair tread to the top surface of the top rail.
1910.29(f)(1)(iii)
The top rail of a stair rail system may serve as a handrail only when:
1910.29(f)(1)(iii)(A)
The height of the stair rail system is not less than 36 inches (91 cm) and not more than 38 inches (97 cm) as measured at the leading edge of the stair tread to the top surface of the top rail (see Figure D-13 of this section); and






RE: handrail requirements per latest OSHA standard
RE: handrail requirements per latest OSHA standard
I was looking at this in December, and that is the conclusion that we reached in the office. Note that the handrails will now push into the tread area (unless your guardrail is off the side of your stringer), so a 20" wide tread becomes even more narrow.
RE: handrail requirements per latest OSHA standard
RE: handrail requirements per latest OSHA standard
RE: handrail requirements per latest OSHA standard
This "encroachment" is explicitly defined in the model codes, but (no surprise) not addressed in OSHA. I take the OSHA width to mean in/in rails or stringers, or guards, or whichever is greater.
RE: handrail requirements per latest OSHA standard
RE: handrail requirements per latest OSHA standard
1910.29(f)(1)(iii)(B)
The top rail of the stair rail system meets the other handrail requirements in paragraph (f) of this section.
Link
RE: handrail requirements per latest OSHA standard
The top rail of a stair rail system may serve as a handrail only when:
1910.29(f)(1)(iii)(A)
The height of the stair rail system is not less than 36 inches (91 cm) and not more than 38 inches (97 cm) as measured at the leading edge of the stair tread to the top surface of the top rail (see Figure D-13 of this section); and
1910.29(f)(1)(iii)(B)
The top rail of the stair rail system meets the other handrail requirements in paragraph (f) of this section.
Doesn't this say if the handrail is 36 to 38 inches high and meets the other requirements of a guardrail then as a single rail system it can be both a hand- and a guard- rail?
RE: handrail requirements per latest OSHA standard
That relies on 1910.29 (f)(1)(iii)(A)-(B), that allows it, if it meets other HANDRAIL requirements in paragraph (f). The requirement for 42" minimum height is not for a handrail, but a "stair rail system". So 36"-38" trumps the 42" requirement. Also, Fig. D-13 shows the single top rail at the 36"-38" height.
Would be good to get clarification from OSHA directly.
RE: handrail requirements per latest OSHA standard
RE: handrail requirements per latest OSHA standard
RE: handrail requirements per latest OSHA standard
Below is a re-hash of my interpretation which is at odds with what you two are saying:
The following is required for platforms installed after Jan 17, 2017:
The height of stair rail systems installed on or after January 17, 2017 is not less than 42 inches (107 cm) from the leading edge of the stair tread to the top surface of the top rail.
This means that the top rail must be at least 42" from leading edge of the stair tread. As such, the following provisions no longer can apply because they require the top rail to be between 36 and 38" from top of stair tread:
The top rail of a stair rail system may serve as a handrail only when:
1910.29(f)(1)(iii)(A)
The height of the stair rail system is not less than 36 inches (91 cm) and not more than 38 inches (97 cm) as measured at the leading edge of the stair tread to the top surface of the top rail (see Figure D-13 of this section); and
1910.29(f)(1)(iii)(B)
The top rail of the stair rail system meets the other handrail requirements in paragraph (f) of this section.
Essentially, 1910.29(f)(1)(ii)(B) says that the top rail must be >42". 1910.29(f)(1)(iii)(A) says that a top rail can serve as a handrail only if the top rail is between 36" and 38".
Because the top rail has to be a min of 42" it cannot serve as a handrail (at least that is my interpretation). Feel free to refute what I have written above -- I would love to be convinced that I don't need the extra hand rail!
RE: handrail requirements per latest OSHA standard
A literal reading of the code following carefully the order and grouping of the clauses leads me to the conclusion that (f)(1)(iii) provides an acceptable alternate to a double rail system. It does not stand on its own but it modifies the preceding statements for specific conditions.
RE: handrail requirements per latest OSHA standard
It's pretty simple. If you have a fall hazard, provide 42" guarding on walking, working, and stair surfaces. Provide a second rail to grasp on stairs.
RE: handrail requirements per latest OSHA standard
RE: handrail requirements per latest OSHA standard
I try not to get inside the head of the writer and while f.1.iii could be read to contradict f.1 perhaps it does not - I've got no problem with it being that for stairs (not platforms or walkways) 42" is the top rail height and the hand rail is 30" to 38" but if the top rail is 36" to 38" it can also be the hand rail. Seems quite reasonable actually and the way they wrote it is about as clean as it could be.
Of course, this is only my opinion and if you have inside knowledge of the process please let us know.
RE: handrail requirements per latest OSHA standard
1910.29(f)(1)(iii)(B) says that you have to comply with all of (f), which includes the requirements for stairs built after January 17, 2017 to have a rail at 42" above the leading edge of the stair.
Of course, upon closer reading, I see that 1910.29(f)(1)(iii)(B) says that the top rail has to comply with the other handrail requirements of (f).... And thus, the OSHA req's devole into a word salad (again).
They should have just said that the geometry for a stair hand and guard rail needs to conform to IBC provisions.
RE: handrail requirements per latest OSHA standard
Item 1:
The exemption in 1910.29(f)(1)(iii)(A) and accompanying Figure D-13 allows a stair rail to serve as handrail when between 36” and 38” in height. Does this exemption apply ONLY to those handrails installed prior to January 17, 2017?
Item 2:
Section 1910.28(b)(11)(ii) references the accompanying Figure D-2 for handrail requirements. In Figure D-2, under the “Two open sides” column, a stairway 44” to 88” wide requires “One stair rail system with handrail on each open side”, while a stairway less than 44” wide requires just “One stair rail system each open side”. Does this correctly indicate that a stairway less than 44” wide with stair rail systems each side does NOT require handrails on either side?
RE: handrail requirements per latest OSHA standard
Well done!
If it is not too late, your first question uses "stair rail" when the language in the standard is "top rail".
Here is another way of saying it:
Is a single rail between 36" and 38" acceptable as a stair rail system if it meets all hand rail requirements? Reference 1910.29(f)(1)(iii) and accompanying Figure D-13.
RE: handrail requirements per latest OSHA standard
If the top rail is not used as a handrail, then the stair-rail needs to be 42" above the nosing line per 1910.29(f)(1)(ii)(B).
The exception is similar to NFPA-101 which allows the top rail of a guard at 42" high on side of a stair to also be used as a handrail. Otherwise the handrail is required to be between 34"-38" high.
All I know is P/A and Mc/I
RE: handrail requirements per latest OSHA standard
Pertinent Links:
Link 1
Link 2
Link 3
That last link is to the federal register of the walking surfaces rule, and is most important as it goes into great detail explaining what they are/were intending to do when the updated the rule. From Section IV: Summary and Explanation of the Final Rule:
(italics added by me)
Link to this specific section here. Note that this appears to clip out the area of the rule discussion. Use Link 3 for access to the entire document.
RE: handrail requirements per latest OSHA standard
Section 1910.29(f)(1)(iii) does appear to be a grandfather clause that only applies to rails installed before Jan. 17, 2017.
My concerns are:
Why has OSHA written (f)(1)(iii) so that it appears to be an exception to (f)(1)(ii)(B)? Why haven't they clearly stated in the section that it only applies to rails installed prior to 1/17/17? Do they really expect people to research a hard to find 513 page Final Rule to obtain this information?
Why hasn't OSHA added another line that allows the top rail of a 42" high stair-rail to also be used as a handrail for rails installed after 1/17/17? They have completely omitted this possibility, which is in NFPA-101, and which is what most of 1910.29(f)is based on.
All I know is P/A and Mc/I
RE: handrail requirements per latest OSHA standard
Is there any case where an OSHA top rail can be a hand rail after Jan 17, 2017 ?
RE: handrail requirements per latest OSHA standard
29CFR section
1910.29(f)(1)(iii) allows the top of a stair rail system to serve as a handrail if the height is 36"-38" above the leading edge of the stair treads. Is this section an exception to 1910.29(f)(1)(ii)(B) which requires the height of stair rail systems installed on or after January 17, 2017 to be 42" minimum above the leading edge of the stair treads? Or does 1910.29(f)(1)(iii) only apply to stair rails in place prior to January 17, 2017? And if 1910.29(f)(1)(iii) only applies to stair rails in place prior to January 17, 2017, Is there a section that allows for the top rail of a stair rail system to also serve as a handrail, for rails installed after January 17, 2017?
This was the reply from OSHA:
The 36-38 inch standard only applies with a grandfathered stair rail. OSHA plans to issue a clarification.
In general grandfathering provisions usually only apply to existing conditions; modifications to existing structures would typically conform to current standards.
All I know is P/A and Mc/I