The Cal-OSHA code, written to protect workers in the state of California, is notoriously more stringent than federal OSHA regulations for guardrail protection and roof fall protection systems. If you've been managing or paying attention to workplace safety issues, you likely know that California regulators have set higher standards, but you may not know where they exceed the federal OSHA guardrail code. Even if you're not located in the Golden State, it can be beneficial to understand the additional safety measures that a product adhering to both Cal-OSHA and federal OSHA guardrail regulations can carry.
First, let's look at the federal regulations for OSHA guardrail compliance; they're relatively straightforward. OSHA is careful to spell out:
"The top edge height of top rails, or equivalent guardrail system members, are 42 inches (107 cm), plus or minus 3 inches (8 cm), above the walking-working surface." - 1910.29(b)(1)
The ideal height for guardrails or roof fall protection systems — according to federal OSHA regulations — is 42 inches, but anywhere between 39 and 45 inches is acceptable for stopping falls to lower levels.
This height was determined to be ideal because it puts the top rail at a position that comes into contact with workers above their center of gravity. A worker who falls with his or her midsection against a guardrail is unlikely to pivot over the top rail when it’s in this height range.
An interesting fact: OSHA notes that rails should be raised an equivalent amount if workers will be wearing stilts. If you have workers who will be regularly standing on raised surfaces, make sure to take that into account and increase the height of the top rail when planning your OSHA guardrail protection system.
Midrails are required when there is no wall or parapet wall that measures at least 21 inches high. According to OSHA, "Midrails are installed at a height midway between the top edge of the guardrail system and the walking-working surface." - 1910.29(b)(2)(i)
The goal of midrails is to eliminate large gaps that an employee could fall through. The midrail must be halfway between the floor and the top rail, and that's one of the reasons why there's a maximum height for a top rail — so workers don't have a large enough gap to fall through. In fact, OSHA also says that there should not be a gap more than 19 inches: "Other equivalent intermediate members (such as additional midrails and architectural panels) are installed so that the openings are not more than 19 inches (48 cm) wide." - 1910.29(b)(2)(iv)
A secondary purpose of the midrail: preventing large objects from falling that could injure a person below.
What good is a guardrail if it will give way when someone falls against it? Guardrails that serve as fall protection must be sturdy enough to hold up against a minimum of 200 pounds of force.
In OSHA's words: "Guardrail systems are capable of withstanding, without failure, a force of at least 200 pounds applied in a downward or outward direction within 2 inches (5 cm) of the top edge, at any point along the top rail." - 1910.29(b)(3)
Additionally, any midrails, screens or solid panels, or other balusters or "intermediate vertical members" must withstand a force of at least 150 pounds.
How are the Cal-OSHA regulations more strict than the federal rules for guardrails and roof fall protection systems? Here's an overview of the same three key areas.
Federal OSHA says the height of the top rail can be between 39 and 45 inches, while Cal-OSHA does not permit top rails to be so low. Their standard states, "A standard guardrail shall consist of top rail, midrail or equivalent protection, and posts, and shall have a vertical height within the range of 42 inches to 45 inches from the upper surface of the top rail to the floor, platform, runway, or ramp level. (Note: the permissible tolerance on height dimensions is one inch)." - Title 24, Part 2, Section 2-1716(a).
In other words, Cal-OSHA allows railings to be 41 to 46 inches in height. Therefore, they must be at least a full 2 inches taller than the federal minimum allows, and can exceed the federal maximum by 1 inch. Again, the goal is to prevent workers who fall from pivoting over the rail, so the average person's center of gravity must be lower than the rail height.
California is a little more cautious than the federal government with this measurement. But they won’t go too high, otherwise the midrail won't prevent gaps large enough to fall through.
Cal-OSHA has a similar guideline in place for midrails as federal OSHA. "The midrail shall be approximately halfway between the top rail and the floor, platform, runway, or ramp." - Title 8, 3209(a) cont.
Depending on how tall your top rail is, you'll want to ensure that the midrail doesn't leave a gap large enough for a person to fall through. Some local construction regulations (cited in California, but may be present elsewhere) require 9-inch spacing of midrails to eliminate this risk.
With force, Cal-OSHA adheres to the concentrated force regulation of at least 200 pounds listed by federal regulations. But there's an additional component; Cal-OSHA also has a regulation in place for the live load applied to the guardrail.
"All guardrails and other permissible types, including their connections and anchorage, shall be designed for a live load of 20 pounds per linear foot applied either horizontally or vertically downward at the top rail." - Title 8, 3209(b)
Unfortunately, you can't calculate live load as easily as concentrated load. You'll need to have the dimensions of the exact guardrail system you'll be installing and then do the math to make sure your rails will bear the 20 pounds per linear foot of force dictated by Cal-OSHA. (In our case, we'll have already done that for you — our systems meet California regulations as well as federal.)
Rather than set a specific force for other components of the railing, Cal-OSHA says that "Railing members shall be framed in such a position that they will afford the greatest support and protection, for example, top rails of structural steel angles shall have the outside face of vertical leg located on the side adjacent to the side of normal contact by the employee." - Title 24, Part 2, Section 2-1716(b).
With the differences in guardrail protection regulations between the federal government and the state of California, it's important to make sure you adhere closely to the regulations for your area. If you’re looking for a system that meets all the requirements for both OSHA and Cal-OSHA, we have a solution to meet your needs.
If you have questions regarding the OSHA and Cal-OSHA differences, feel free to contact us for more information.
