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.

November 5, 1991

Mr. J. F. Mainieri
Sr. Protective Coating Specialist
American Electric Power Service Corporation
1 Riverside Plaza
Columbus, Ohio 43215

Dear Mr. Mainieri:

This is in response to your inquiry of September 25, in which you requested an interpretation of 29 CFR 1910.144(a)(3). This standard states that yellow shall be the basic color for designating caution and for marking physical hazards such as: striking against, stumbling, falling, tripping and "caught in between."

Your concern is whether or not the standard requires that all permanent handrails be painted yellow. You express your belief that OSHA does not have such a requirement. The answer to your question is that 1910.144(a)(3) was not meant to state directly or by implication that all permanent handrails be painted yellow. Your assumption is therefore correct.

Sincerely,



Patricia K. Clark
Director
Directorate of Compliance Programs