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.

September 18, 1984

Brian Mentis, Vice President
Integrated Technical Services, Inc.
Post Office Box 10177
Houston, Texas 77206-0177 USA

Dear Mr. Mentis:

This in response to your letter of August 20, 1984, requesting this office to evaluate the ball-type handrail system for use in this country. This also confirms your telephone conversation with Mr. William Simms of my staff.

It is the policy of OSHA not to approve or endorse products. The variable working conditions at jobsites and possible alteration or misapplication of an otherwise safe product could easily create a hazardous condition beyond the control of the product manufacturer.

29 CFR 1926.500(f)(1)(vi) provides that other types, sizes, and arrangements of railing construction are acceptable, provided they meet the following conditions:

(a) A smooth-surfaced top rail at a height above floor, platform, runway, or ramp level of approximately 42 inches. (40 inches high is acceptable.)

(b) A strength to withstand at least the minimum requirement of 200 pounds top rail pressure with a minimum of deflection. (1-11/32 tubing complying with (b) is acceptable.)

(c) Protection between top rail and floor, platform, runway, ramp, or stair treads, equivalent at least to that afforded by a standard intermediate rail.

(d) Elimination of overhang of rail ends unless such overhang does not constitute a hazard.

Railing construction meeting the above criteria may also be used for the protection of employees engaged in general construction work.

In addition, 29 CFR 1926.500(f)(2) requires a stair railing to be of construction similar to a standard railing, but the vertical height shall be not more than 34 inches nor less than 30 inches from upper surface of top rail to surface of tread in line with face of riser at forward edge of tread.

If we can be of further assistance, please let us know.


John B. Miles, Jr., Director
Directorate of Field Operations