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OSHA Instruction STD 1-1.10 June 30, 1981 Office of Compliance Programming

Subject: Height of Guardrails in General Industry Applications

A. Purpose. This instruction provides guidance for the equitable enforcement of 29 CFR 1910.23(e)(1) as it pertains to the acceptable height of guardrails.

B. Scope. This instruction applies OSHA-wide.

C. Action. OSHA Regional Administrators/Area Directors shall classify technical violations of 29 CFR 1910.23 (e)(1) as de minimis violations, where the employer has provided guardrails which meet the following specifications:

1. Existing guardrailing shall consist of a top rail, intermediate rail, and posts, or equivalent, and shall have a minimum vertical height of 36 inches to 44 inches from the upper surface of the top rail to the floor, platform, runway or ramp level.

2. Guardrailings with heights greater than 44 inches are permissible provided the extra height does not create a dangerous situation for employees. Openings beneath the top rail that would permit the passage of a 19 inch or larger spherical object would create an unsafe condition, therefore, additional mid-rails may be necessary.

3. Deviations from the standard which are deemed to be de minimis violations, as herein described, apply only to the General Industry standards, 29 CFR 1910, and do not affect the specified requirements for guardrailings set forth in the Maritime or Construction standards.

D. Federal Program Change. This instruction describes a Federal program change which affects State Programs. Each Regional Administrator shall:

1. Ensure that this change is forwarded to each State designee.

OSHA Instruction STD 1-1.10 June 30, 1981 Office of Compliance Programming

2. Explain the technical content of the change to the State designee as requested.

3. Ensure that State designees are asked to acknowledge receipt of this Federal program change in writing, within 30 days of notification, to the Regional Administrator. This acknowledgment should include a description either of the State's plan to implement the change or of the reasons why the change should not apply to that state.

4. Review policies, instructions and guidelines issued by the State to determine if this change has been communicated to State program personnel. Routine monitoring activities (accompanied inspections and case file reviews) shall also be used to determine if this change has been implemented in actual performance.

E. Background. A Field Information Memorandum #74-87 (FIM) was previously issued regarding the height of guardrails. At the time FIM's were reissued and converted to OSHA #100 Series Program Directives, FIM #74-87 was not converted pending the issuance of a major revision to Subpart D of 29 CFR 1910. The intended revision is not yet available; therefore, to provide equitable enforcement which does not place unnecessary cost burdens upon employers, or have a direct or immediate effect upon the safety or health of employees, this instruction reissues the previous policy of FIM #74-87 and presents compatible criteria to the anticipated revision of Subpart D.

1. The stipulations set forth herein provide for compatible specifications between ANSI, the NFPA, and OSHA, regarding the acceptable height of guardrails in workplaces.

2. In consideration of the findings by the National Bureau of Standards research study, Report Number NBSIR 76-1139, Investigation of Guardrails for the Protection of Employees from Occupational Hazards,

OSHA Instruction STD 1-1.10 June 30, 1981 Office of Compliance Programming

dated July 1976, this instruction permits the application of some applicable determinations in advance of the eventual promulgation of a revision to Subpart D of 29 CFR 1910.

Thorne G. Auchter Secretary

DISTRIBUTION: National, Regional and Area Offices All Compliance Officers State Designees NIOSH Regional Program Directors