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.

October 17, 2024

Ryan D. Harting, PE
Borton- Lawson
3897 Adler Place
Bethlehem, Pennsylvania 18017

Dear Mr. Harting:

Thank you for your inquiry to the Occupational Safety and Health Administration (OSHA) regarding stair width and handrails. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased question and OSHA’s response are below:

Question: The note at the bottom of Table D-2 - Stairway Handrail Requirements in §1910.28(b)(11)(ii) states, "The width of the stair must be clear of all obstructions except handrails." Based on this note, how should the standard stair width be measured to comply with §1910.25(c)(4)?

Response: OSHA standard at 29 CFR 1910.25(c)(4) applies to places of employment and requires standard stairs to have a minimum width of 22 inches (56 cm) between vertical barriers. OSHA does not consider a handrail to be a vertical barrier or obstruction to that required minimum width. The note at the bottom of 1910.28(b)(11)(ii) Table D-2 is meant to indicate that the handrails are not considered obstructions or vertical barriers for purposes of measuring standard stair width. The preamble to the final rule states "[§ 1910.25(c)(4)], ... requires that employers ensure standard stairs have a minimum width of 22 inches between vertical barriers. Examples of vertical barriers include stair rails, guardrails, and walls." 81 Fed. Reg. 82494, 82560 (Nov. 18, 2016). The standard stair width is measured between the vertical barriers, not between handrails. Please note that stair width requirements are different for means of egress and shall be in accordance with OSHA standard 1910.35.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to 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. If you have any further questions, please feel free to contact the Office of General Industry and Agricultural Enforcement at (202) 693-1850.

Sincerely,

Scott C. Ketcham, Director
Directorate of Enforcement Programs