Alternative guardrail designs and state plan rules

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 16, 1983

Mr. Paul D. Kincheloe
Safety Director
PECO Industries, Inc.
[Recipient address omitted]
Dear Mr. Kincheloe:

This in response to your letter of August 26, 1983, requesting a clarification of our railing requirements in 29 CFR 1910.23(e).

A variable arrangement system as mentioned in your correspondence would be acceptable if it meets the requirements of 29 CFR 1910.23(e)(3)(v)(a), (b), and (c), as follows:

(v) Other types, sizes, and arrangements of railing construction are acceptable provided they meet the following conditions:

(a) A smooth-surfaced top rail at a height above floor, platform, runway, or ramp level of 42 inches nominal;

(b) A strength to withstand at least the minimum requirement of 200 pounds top rail pressure;

(c) Protection between top rail and floor, platform, runway, ramp, or stair treads, equivalent at least to that afforded by a standard intermediate rail.

As you know, there are [25] State plan jurisdictions which administer their own occupational safety and health programs under approval and subject to monitoring by OSHA. These States must adopt occupational safety and health standards which are at least as effective as the corresponding Federal standards. Most of the [25] State plan jurisdictions adopt and enforce standards that are identical to the Federal. However, six of the states adopt and enforce at least some standards that are different from the Federal counterparts. These six States are: Alaska, California, Hawaii, Michigan, Oregon and Washington. For information on these States' specific requirements relative to 29 CFR 1910.23(e)(2)(v), you should contact them directly. The addresses and telephone numbers for all 24 of the State plan jurisdictions are listed in the enclosed directory.

If we may be of further assistance, please contact [the Office of General Industry Compliance Assistance at (202) 693-1850].

Sincerely,

John K. Barto
Chief, Division of Occupational
Safety Programming