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 http://www.osha.gov.

May 30, 1979

Mr. Robert D. Brent
Chief Draftsman
Custodis Construction Co.
Research - Cottrell
222 S. Riverside Plaza
Chicago, Illinois 60606

Dear Mr. Brent:

This is in response to your inquiry addressed to our Chicago Regional Office concerning sectionalized rail systems. This also confirms a telephone conversation between you and a member of my staff.

In 29 CFR 1910.23(e)(1), there is a requirement that the top rail of a standard railing be smooth-surfaced throughout the length of the railing. This means that the surface of the rail regardless of the shape shall be free from projections or irregularities that could injure employees' hands.

The sectionalized rail systems depicted in drawings 2A, 2B, 3A, and 3B free from projections or irregularities that could be injurious to hands appear to meet the smooth-surfaced requirement in 29 CFR 1910.23(e)(1).

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

Sincerely,



Grover C. Wrenn Director,
Federal Compliance
and State Programs