Handrail Extensions per OSHA

[aswierski]

I am doing some safety inspections on a refinery in Indiana. Per our client's standards, handrail extensions are required on elevated platforms. See attached for clarification. Now, I came across many situations where this was not done, and the client and I have come to the general consensus that if these handrail extensions are not OSHA required, we will not require the contractor to install them. I have read through sections 1910.27 (Fixed Ladders), 1910.37 , and 1910.38 in OSHA's General Industry Regulations but have been unsuccessful in finding any clarification. Has anyone run into this before? Can anyone point me in the right direction of some helpful literature? Thanks in advance.

 

[aswierski]

Here is a picture of an example.

 

[aswierski]

Whoops, here is the correct picture. Ignore my previous post.

 

[racookpe1978]

Your photo shows the ladder going down from the platform, but the extended ("extended up from the normal handrails") handrail is for the gap between a normal handrail and a ladder "frame" going up to the next level.

So, for your application - at this location at least - there is no need.

 

[Ron]

1910.27(d)(2)(ii)
All landing platforms shall be equipped with standard railings and toeboards, so arranged as to give safe access to the ladder. Platforms shall be not less than 24 inches in width and 30 inches in length.

Since this is a landing platform, it requires full handrail and toeboard. If the gate interrupts those, then the gate should be configured to provide the same protection when closed.

 

[Bagman2524]

Pleae clarify your question. Is the handrail extension being used to close an opening where the ladder is? In this case a gate should be used as mentioned above.

Handrail extensions are typically used at the top or bottom of stairs. They are required by IBC/ADA. I'm not aware of any handrail extensions being required by OHSA.

Also, note that "handrails" and "guardrails" are not the same thing. Handrails are intended to be a gripping point to provide extra stablization while walking. Guardrails are a barrier to prevent falling to a lower level.

 

[aswierski]

Bagman,

You are correct, these are technically guardrails. For clarification, I've attached a sketch that closely resembles the photo. Per OSHA's 4' requirement per Figure D-9 (General Industry Regs Section 1910.27) there should be some kind of extended guardrail (at least how interpret it). Since Ladder A gets in the way of this, are you suggesting that making the swing gate height to match the extension height is standard practice? You'll have to forgive my ignorance, but I've been asked to do these safety inspections to make sure we're in compliance with OSHA. The idea is that we will fix any items I find before OSHA comes in. I've never done anything like this, nor has anyone else in my company for that matter, so I just want to make sure I'm not missing anything...

 

[JStephen]

The way I remember it, OSHA shows a ladder cage extending down to the handrail for certain elevated platforms, I don't recall if they say which ones this applies to, though. I assume the guardrail you are looking at is a substitute for the cage extension?

 

[Bagman2524]

This looks to me like you need a 42" high guardrail where your sketch shows the extension; and the sides ladder B down needs to extend above the plate by at least 42"; and you need a swing gate at the entrance of this ladder. I'm not sure if the swing gate would need to be 42" high or not. The idea is that you don't have any open/unguarded spaces where someone can fall to the level below.

What is the 4' radius that you are showing? Ladder B up probably needs a cage starting at 7 ft above the plate. The cage is required if the distance from the floor/platform at the top level B up to the floor below the plate shown in your sketch is greater than 20 ft.