Standard Interpretations - Table of Contents|
| Standard Number:||1910.23(e)(1); 1910.24(h); 1926.1052; 1926.1052(c)(6); 1926.1052(c)(7); 1926.1052(c)|
|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.|
(c) Stairrails and handrails.Under these provisions, while construction work is being performed, a separate handrail must be provided if the top rail of a stairway system exceeds 37 inches. Since the top rail you refer to is 42 inches, a separate stair rail would be required. The different height requirements reflect different purposes.
* * *(6) The height of handrails shall be not more than 37 inches (94 cm) nor less than 30 inches (76 cm) from the upper surface of the handrail to the surface of the tread, in line with the face of the riser at the forward edge of the tread.
(7) When the top edge of a stair rail system also serves as a handrail, the height of the top edge shall be not more than 37 inches (94 cm) nor less than 36 inches (91.5 cm) from the upper surface of the stair rail system to the surface of the tread, in line with the face of the riser at the forward edge of the tread. [Emphasis added.]
...[A] study by the University of Michigan (Ex. 3-6:43) indicates that 33 inches is the optimum height for handrails, and that a variance from this height of plus-or-minus 3 inches is appropriate. Paragraph (c)(6) requires that handrails be between 30 inches and 37 inches in height throughout the length of the stairway...While you referenced both General Industry (29 CFR Part 1910) and Construction Industry (Part 1926) provisions, this letter addresses only the standards applicable to the construction industry. The general industry standards you cited, §§1910.23(e)(1) and 1910.24(h), do not apply to construction work; we have forwarded your letter to the Office of General Industry Enforcement for a response regarding those provisions.
* * *Paragraph (c)(7) allows any stairrail system between 36 and 37 inches in height to double as a handrail. OSHA intends the proposed 37-inch upper limit for handrails to provide a measure of flexibility, allowing a 1-inch tolerance for the height of a stairrail that also serves as a handrail. There were no comments on paragraph (c)(7). OSHA has revised paragraph (c)(7) to indicate clearly that stairrails that comply with its terms may also be used as handrails.
|Standard Interpretations - Table of Contents|