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RE: Railings on Stairs - OSHA 1910.23 & the Florida Building Cod

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I would venture that unless you are working on a project that has specific OSHA compliance mandates, that there is no legal liability roadway for you to get to the OSHA requirement.  In other words, the State adopts a building code, you comply with that code.  PERIOD.  Absent a clause in the state code which explicitly guides you to compliance to OSHA, (such as, for instance, the clauses that adopt ASTM or ASME, etc.)  then your responsibility defaults to the state code and ONLY that.   It is the State that is required to make THEIR statutes match up with Federal Law if and when necessary, hence the many references that make the hard-tied legal connection.

 

But, having said this, be careful.  There are a lot of spots where such a clause could be hiding in a state code that you can’t find, (which is to say, don’t care to waste your time trying to find).

 


From: Robert Kazanjy [mailto:rkazanjy(--nospam--at)gmail.com]
Sent: Wednesday, August 29, 2007 1:04 PM
To: seaint(--nospam--at)seaint.org
Subject: Re: Railings on Stairs - OSHA 1910.23 & the Florida Building Cod

 

OSHA (two sections) & FBC are all inconsistent

The U of Michigan study  cites  33" +/- 3"   (30 to 36")

I guess the question which code does he want to violate?

& by how much?

I would put a little more faith in a study cited by OSHA than a single passage in a code section.  

Oh well, the joys of design by code.

cheers
Bob




On 8/29/07, John Sieszycki <jsieszycki(--nospam--at)yahoo.com > wrote:

FBC required 34" min. and 38" max.
Using 34" +- 1" seems to be risky. I will use 35" with
not less than 34" during installation.

John W. Sieszycki

--- Robert Kazanjy < rkazanjy(--nospam--at)gmail.com> wrote:

> David-
>
> Check this out
>
>
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24960
>
>
> Of course the interpretation is from 2004 AND it is
> a construction
> requirement question about
>
> §1926.1052(c)(6) and 1926.1052(c)(7)
>
> 1926.1052
> (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.
>
> The FBC requirement of 34 to 38 seems biased
> slightly towards the upper
> range of comfortable hand rail heights.
>
> In the OSHA interpretation letter they cite a U of
> Michigan study that
> suggests 33" is optimum with allowable range of +/-
> 3"
>
> but they also mention that section in the
> interpretation addresses only the
> standards applicable to the construction industry
>
> and that General Industry (29 CFR Part 1910) needs
> an additional
> interpretation
>
> So there even appears to be a conflict within OSHA
>
>
> My suggestion:  go with  a rail height of  34"  with
> a installation
> tolerance of +/- 1" & call it good.
>
>
> cheers
> Bob
>
>
>
>
> On 8/27/07, M. David Finley, P.E., P.A. <
> davidfinley(--nospam--at)bizsea.rr.com> wrote:
>
>  OSHA 1910.23 (e) (2)  requires railings on stairs
> to be "not more than 34"
> > nor less than 30" inches from the upper surface of
> top rail to surface of
> > tread in line with face of riser at forward edge
> of tread"
> >
> > The Florida Building Code (2005 Supplement)
> 1009.11.1 requires "Handrail
> > height, measured above stair tread nosings, or
> finish surface of ramp slope
> > shall be uniform, not less than 34" and not more
> than 38 inches"  It also
> > allows an exception:  "Handrails for stairs not
> required to be accessible
> > that form part of a guardrail may be 42" high"
> >
> >
> > Therefore, for an industrial building in Florida,
> it appears to me that I
> > have to have the stair railing at exactly 34" or I
> will be in violation
> > of either the OSHA or FBC requirements.  Has
> anyone had to deal with this
> > before?  Am I mis-interpreting these sections?  Is
> there an exception to the
> > FBC for industrial facilities?
> >
> > TIA,
> >
> > David Finley
> > M. David Finley, P.E., P.A.
> > 2086 SW Main Boulevard - Suite 111
> > Lake City, FL  32025
> > 386-752-6400
> >
> >
>




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