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.

December 3, 1975

Mr. Ralph W. McMickle
Senior Structures Engineer
Ford, Bacon & Davis Construction Corporation
P.O. Box 1762
Monroe, Louisiana 71201

Dear Mr. McMickle:

This is in response to your letter of April 23, 1975, addressed to Mr. Jim Powell, Area Director, New Orleans, Louisiana regarding OSHA requirements for railings. In addition, it confirms your telephone conversation with a member of my staff.

Your basic question requesting an interpretation of 29 CFR 1910.23(e)(3)(v) has been reviewed, especially the (b) part of (v), which reads "A strength to withstand at least the minimum requirement of 200 pounds top rail pressure." The minimum requirement of 200 pounds top rail pressure refers to 1910.23(e)(3)(iv), which reads "The anchoring of parts and framing of members for railings of all types shall be of such construction that the completed structure shall be capable of withstanding a load of at least 200 pounds applied in any direction at any point on the top rail."

There are no specific guidelines for relating the 200 pounds strength requirement to a stress design criteria. The yield strength of a material is a good guide, providing the railing protecting the employee is in compliance with the above 1910.23(e)(3)(iv) standard.

If I may be of any further assistance, please feel free to contact me.


John K. Barto, Chief
Division of Occupational
Safety Programming