Smooth-surfaced stair rails and slip-on fittings

November 14, 2005

Mr. Ron Crebo

Hollander Structural Fittings

[Recipient address omitted]

Dear Mr. Crebo:

Thank you for your July 27, 2005, letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. Your letter was forwarded to the Office of General Industry Enforcement for response. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You had specific questions regarding structural slip on fittings on stair rails.

The question below has been restated for clarity.

Question: Are slip on fittings for stair rails in compliance with §1910.23(e)(1), which requires stair rails to be smooth surfaced?

Response: As you may be aware, OSHA does not approve or endorse any products or test results. The variable working conditions at jobsites and possible alterations or misapplication of an otherwise safe product could easily create a hazardous condition beyond the control of the manufacturer.

The requirement in §1910.23(e)(1) for stair rails to be smooth surfaced means that the surface of the rail must be free from projections or irregularities that could cause injury to employees, such as punctures or lacerations, or that could cause a slip or fall by snagging clothing, jewelry or items carried by an employee. Fittings that do not create these potential hazards would be allowed, but we are unable to evaluate your product from the brochure alone.

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 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 www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director

Directorate of Enforcement Programs