
Clear as Mud?
I thought about making this a Quiz Question, however, I am still reeling at my surprise. I was looking into research on Jordan Lichlyter’s question here on SK on handrails below. I know almost nothing about 1926, so I was trying to find out how the question might apply in 1910. It was difficult as in 1910 we do not use rebar very much, except to manufacture it in the first place.
But then I found this Letter of Interpretation on OSHA.gov.
https://www.osha.gov/laws-regs/standardinterpretations/2019-09-23
Who knew that you need a guardrail AND a handrail on stairways built after January 17, 2017, per this Letter of Interpretation?
Later OSHA says in this letter:
Enforcement Guidance
For stair rail systems installed on or after January 17, 2017, that meet §1910.29(f)(1)(iii)(A) instead of §§1910.29(f)(1)(i) and 1910.29(f)(1)(ii)(B), OSHA will not issue citations until the intent of the standards is clarified by a FRN. That is, heights of handrails and top rails of stair rail systems installed prior to any future FRN that meet either Figure 1 or 2 will be deemed compliant and will not need to be retrofitted.
Clear as mud, right?
Per this letter you should build your stairs in your plant like in Figure 2 if the picture above from the Letter of Interpretation. Has a FRN been issued? Is anyone out there making stairs like this?

Comments (1)

That dabbles over into the building code, as well.