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.

October 1, 1991

                   Regional Administrator

THROUGH:            LEO CAREY, Director
                   Field Programs

FROM:               PATRICIA K. CLARK, Director 
                   Directorate of Compliance Programs

SUBJECT:            29 CFR 1926.1052, Stairways

This memorandum is in response to your July 30, 1991, memorandum requesting interpretative guidance on the final rule for stairways used in construction.

Please be advised that railings must be provided on all stairway platforms and landings that are 30 inches or more in height. As stated in your memorandum, paragraph 1926.1052(a)(4) requires platforms where doors or gates open directly onto stairways; paragraph 1926.1052(c)(12) requires guardrails to be installed on the unprotected sides and edges of stairway landings; and paragraph 1926.1052(c)(1) requires handrail and stairrail systems along each unprotected side or edge of the stairway 30 inches or more in height. These provisions establish the need for railings on stairways 30 inches or more in height (note: the terms "platform" and "landing" are interchangeable). The reference to Subpart M contained in paragraph 1926.1052(c)(12) is intended to be a reference to the specifications for standard railings contained in paragraph 1926.500(f) that address such criteria as minimum height and strength. The reference is not to the provisions of paragraph 1926.500(d)(1) which establishes six feet as the height at which fall protection is required on other elevated surfaces.