- Standard Number:
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 https://www.osha.gov.
April 22, 1975
- MEMORANDUM FOR:
- ALFRED BARDEN
ASSISTANT REGIONAL DIRECTOR
- Compliance with OSHA Requirements
This is in response to your memorandum of March 18, 1975, concerning 1910.23(e), Railing Specifications.
After reviewing your correspondence with enclosures, the following are suggested guidelines:
- A handrail and a stair railing have two different meanings. Reference definitions in 1910.21(a)(3) and 1910.21(a)(8).
- A handrail and a railing as applied to fixed industrial stairs have two different meanings. Reference definitions in 1910.21(b)(1) and 1910.21(b)(5).
- Stairs other than fixed industrial stairs have different requirements for being equipped with standard stair railing or standard handrails when compared to the requirements of fixed industrial stairs. Reference 1910.23(d) and 1910.24(h).
- The specifications for a stair railing is different than the specifications for a handrail. Reference 1910.23(e)(2) and 1910.23(e)(5)(i) through 1910.23(e)(5)(iv).
- The posts are an integral part of a stair railing as the brackets are an integral part of a handrail. Reference 1910.23(e)(1) as referenced by 1910.23(e)(2) and 1910.23(e)(5)(i). The posts and brackets are not considered as "any other object" as this term is used in 1910.23(e)(6), and the posts and brackets are not required to have a clearance of not less than 3 inches between the top rail or handrail, respectively.
Therefore, it is strongly recommended now, as it was suggested in the meeting, that you investigate your manufacturing processes so that your top rail will meet the present requirements for handrails as stated in 29 CFR 1910.23(e)(6).
Barry J. White
Associate Assistant Secretary
for Regional Programs