FAQs on new OSHA Fall Protection Regulations: Vol. 9 – Guardrail

In this installment of our blog series, let’s focus on more specific details – design changes that affect guardrail.

If you’re wondering about how guardrail is affected, there are several new developments in the updated rule. First, guardrail height is officially required at 42 inches (+/- 3), which is now aligned with construction industry regulations. By codifying this requirement, the rule has effectively removed the grandfather clause from the proposed general industry regulations that allowed 36-inch high guardrail.

I think this is a misguided decision for many reasons. First, I believe the goal is protection, and it’s there with a 36-inch height. Sure, the additional 3+ inches of height improves the safety, but not significantly enough to require retrofit. I’m aware of many organizations who accepted the grandfather height and implemented the shorter guardrail, assuming they were in compliance. Now, they are required to replace or somehow augment the existing guardrail in order to comply with the new rule.

This wasn’t the only alternative that was removed in the new rule. In addition, the former so-called parapet option—where a shorter parapet could be considered sufficient as long as it was 18 inches deep—is no longer allowed. It is specifically excluded in the new rule. Again, this leaves organizations with no choice but to adjust any situations where they employed this parapet alternative–or risk noncompliance. While I agree that the 42-inch guardrail is best, I don’t agree that the places where the former solutions are used should require the time and expense of retrofit, since the protections are still there. Regardless of my opinion, the updated rules are effective, so if you haven’t already, I recommend that you locate any of these instances on your sites and make a plan for an updated solution.

I mentioned this final point in the last post, but want to include it here, since it’s relevant to guardrail. And, we have seen this to be one of the major noncompliance issues when we’ve completed walking-working surface assessments for clients after the release of the regulations.

OSHA1910.29 (b)(13) says that when guardrail systems are used around holes or openings that serve as points of access (such as ladderways), the guardrail system opening must have the following characteristics:

  • Has a self-closing gate that slides or swings away from the hole
  • Is equipped with a top rail and midrail or equivalent intermediate member that meets the requirements

It’s important to note that, as an alternative, you can also offset the ladder opening to prevent a worker from walking or falling into the hole

Please subscribe or check back next Wednesday morning for the next installment in this blog series, which focuses on requirements related to stairs. And, if you have your own specific questions, please comment below.

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