OSHA's Official Ruling

Question (11/9/99): Is it necessary to protect a roof hatch opening?

OSHA'S Answer
(6/12/00): "Yes...
Unprotected openings in roofs could, therefore, be cited under the general duty clause of the Occupational Safety and Health Act...by Richard E. Fairfax, Director of Compliance Programs (OSHA)

Reference: ANSI A1264-.1-1995
Reference: 29 CFR 1910.23


Our Railing System Meets OSHA Standards
On July 12, 2000 OSHA issued a formal ruling on railings required for roof hatches. 
The TriStar "Roof Hatch Safety Railing System" meets all OSHA Standards and local, national and international building codes.

 

Our product meets OSHA and BOCA standards

1. 
Serves as substantial protection of the open hatch.  Serves as an extension of a ladder to a "platform", and provides something substantial to hold while exiting or entering a hatch
2. 
Exceeds minimum strength requirements for railings.
3. 
Is galvanized for weather resistance.
4. 
Is unobstructed from top to bottom.
5. 
Contains no sharp edges or snag points.


 Interpretation of OSHA Regulations 1910.23 & 1910.27
.

The Roof Hatch Safety Railing System is designed to meet OSHA requirements and to provide safe egress and ingress through roof and access hatches.

Guarding Floor and Wall Openings and Holes
OSHA Regulation 1910.23 Guarding floor and wall openings and holes, states that:
(a)(2) Every ladderway floor opening or platform shall be guarded by a standard railing with standard toeboard on all exposed sides (except at entrance to opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening.
(a)(3) Every hatchway and chute floor opening shall be guarded by one of the following: 1910.23
(a)(3)(I) Hinged floor opening cover of standard strength and construction equipped with standard railings or permanently attached thereto so as to leave only one exposed side. When the opening is not in use, the cover shall be closed or the exposed side shall be guarded at both top and intermediate positions by removable standard railings.

Interpretation
The roof hatchway is a "ladderway floor opening", the roof being the floor or platform. Therefore, when the hatch is open, the hatchway must be protected by guard railings as above. The Roof Hatch Safety Railing System as designed by Nesea Corporation protects the open hatchway per OSHA regulation 1910.23 utilizing permanent railings in lieu of removable railings. Permanent railings are always there and are inherently more safe than removable railings. The toeboard referred to in the regulation is actually the roof curb of the roof hatch. Accessories are available to equip the standard railing system at the opening with a swinging gate or chain and to provide mid railings on the guard railings if desired.

Stairways and Ladders
In reference to OSHA Regulation 1910.27 and on Page 7 of OSHA publication 3124 in reference to Fixed Ladders states that: "Individual rung/step ladders must extend at least 42 inches (1.1 m) above an access level or landing platform either by the continuation of the rung spacings as horizontal grab bars or by providing vertical grab bars that must have the same lateral spacing as the vertical legs of the ladder rails. And that (page 8 last paragraph) "The side rails of through or side-step fixed ladders must extend 42 inches (1.1 m) above the top level or landing platform served by the ladder." And that (page 9 first 2 paragraphs) "Steps or rungs for through-fixed-ladder extensions must be omitted from the extension; and the extension of side rails must be flared to provide between 24 inches (61 cm) and 30 inches (76 cm) clearance between side rails. And that "When safety devices are provided, the maximum clearance distance between side rail extensions must not exceed 36 inches (91 cm).

Interpretation
The Roof Hatch Safety Railing System designed by Nesea Corporation provides fixed ladder extensions to comply with OSHA Standard 1910.27. Accessories are available to provide the Safety Railing System with grab railing extensions to bring the vertical grab railings to within the 24" to 36" requirement if necessary for the particular application.

In Summary
The Roof Hatch Safety Railing System designed by Nesea Corporation meets OSHA Standards 1910.23 and 1910.27 by protecting the hole while the roof hatch is open and by providing the proper extension of a fixed ladder to a platform. In this case the platform is the roof.

Statement From Professional Engineer
"The Roof Hatch Safety Railing System meets OSHA Safety Standards for strength, design, and durability. It's a very comfortable product to use and makes climbing in and out of access hatches much easier and safer".  (Mechanical and Civil), October 5, 1998

Below is a copy of the OSHA letter


 

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