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• Standard Number: 1910.24(h); 1910.23(e)(2)

November 9, 1999

Mr. Steve Bonura
CONDEA Vista Company
2201 Old Spanish Trail
Westlake, Louisiana 70669

Dear Mr. Bonura:

Thank you for your September 10, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs (DCP). You have asked OSHA to resolve an apparent conflict between two of OSHA's standards, and to clearly define which standard should apply to your situation. The conflict in question concerns railings on stairways and involves 29 CFR §1910.23 (guarding floor and wall openings and holes), and §1910.24 (fixed industrial stairs).

OSHA's standard §1910.24 addresses Fixed industrial stairs. Subsection (h) addresses railings and hand railings as follows:

§1910.24(h) Standard railings shall be provided on the open sides of all exposed stairways and stair platforms. Handrails shall be provided on at least one side of closed stairways preferably on the right side descending. Stair railings and handrails shall be installed in accordance with the provisions of §1910.23.

OSHA's standard §1910.23 addresses Guarding floor and wall openings and holes, and subsection (e) addresses railings, toe boards, and cover specifications. Although subsection (e)(1) addresses standard railings, it is subsection (e)(2) that addresses stair railings as follows:

§1910.23(e)(2) A stair railing shall 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.

There is no conflict between §1910.24 and §1910.23 with regard to height of stair handrails, because §1910.24 refers back to §1910.23, stating that stair railings are to be installed in accordance with §1910.23. That part of §1910.23 that addresses stair railings is subsection (e)(2) and not (e)(1). Therefore, if your stair railings are 30-34" as specified in §1910.23(e)(2), you are in compliance with §1910.24.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may 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 Compliance Assistance at (202) 693-1850.

Sincerely,

Richard Fairfax, Director
Directorate of Compliance Programs


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