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RE: Railing clearances

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I agree with Jason in general that OSHA applies "with respect to employments
performed in a workplace", i.e. applies to most structures where people
work. However, it is my understanding that OSHA will generally defer to
governing building code requirements where they apply, even though that is
not spelled out anywhere. Thus I generally use the building code
requirements for enclosed structures used by people (i.e., "occupancies")
and use OSHA for such things as equipment access platforms, exterior
industrial facilities, etc.  

Unfortunately, there are several discrepancies between OSHA and typical
building code requirements, like the one noted for railings, which make it
difficult to meet all legal requirements to the letter. It would be nice if
the OSHA regulators coordinated with the standard building codes and defined
better where their provisions should or should not govern. Similarly, it
would help if the building codes better defined where their requirements
should not apply. For now, we just have to use our best judgment. 

William C. Sherman, PE 
(Bill Sherman) 
CDM, Denver, CO
Phone: 303-298-1311
Fax: 303-293-8236
email: shermanwc(--nospam--at)

> -----Original Message-----
> From: Jason W. Kilgore [mailto:jkilgore(--nospam--at)] 
> Sent: Monday, December 22, 2003 10:59 AM
> To: seaint(--nospam--at)
> Subject: RE: Railing clearances
> > OSHA regulates work related sites such as construction or 
> industrial 
> > use sites. It is mainly intended for worker safety. UBC is 
> related to 
> > buildings and its occupants. You need to determine which 
> one of these 
> > you are dealing with and design accordingly.
> While I agree that the OSHA regulations are primarily 
> designed for construction or industrial sites, people also 
> work in office buildings. Therefore, OSHA covers office buildings.
> My interpretation here is the 3" in OSHA is to give plenty of 
> clearance for a gloved hand during an emergency grab.  The 
> 1.5" in UBC is for normal finger clearance during normal use.
> If you're a pessimist, you need to detail to whichever is 
> more stringent. In other words, detail to the requirements 
> the lawyer will cite when you get sued.  Otherwise, detail to 
> whichever use you deem best fits the location.
> ---
> Jason Kilgore
> Leigh & O'Kane, LLC
> Kansas City, Missouri

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