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OSHA 1917.112

Edge and fall protection

Subpart F

22 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.112(a)(1), how high must vehicle curbs or bull rails be at waterside edges of aprons and bulkheads?

Vehicle curbs, bull rails, or other effective barriers must be at least six inches high at waterside edges, but curbs or bull rails installed after October 3, 1983 must be at least 10 inches high. Per 1917.112(a)(1), provide the required height and ensure the barrier is effective; if vehicles are prohibited at the edge, this requirement does not apply.

Under 1917.112(a)(2), does the vehicle curb or bull rail requirement apply to the edge of any fixed level above a common floor area?

Yes — the curb/bull rail requirement also applies at the edge of any fixed level above the common floor area from which vehicles may fall, except at loading docks, platforms and skids where cargo is moved by vehicles. See 1917.112(a)(2) for this extension of the vehicle protection rule.

Under 1917.112(b)(1), when must guardrails be provided to protect employees at edges and openings?

Guardrails must be provided where employees are exposed to floor or wall openings or waterside edges that present a hazard of falling more than 4 feet or falling into the water. This is stated in 1917.112(b)(1).

Under 1917.112(b)(2), where are guardrails explicitly not required?

Guardrails are not required at loading platforms and docks, at waterside edges used for cargo handling, on the working sides of work platforms/skids, or on railroad rolling stock, highway vehicles, intermodal containers or similar equipment. See the exceptions listed in 1917.112(b)(2) and its subparts (i–iv).

Under 1917.112(b)(3), what must an employer do if guardrails are impracticable due to machinery or work processes?

If guardrails are impracticable because of machinery requirements or work processes, employers must use an alternate means of fall protection such as nets. This requirement is in 1917.112(b)(3).

Under 1917.112(c)(1), how strong must guardrails be?

Guardrails must be capable of withstanding a force of at least 200 pounds applied in any direction at mid-span of the top rail (or at the uppermost point if there is no top rail). This performance requirement is specified in 1917.112(c)(1).

Under 1917.112(c)(2), what construction is required for guardrails that are not solid baluster or grillwork?

Guardrails that are not solid baluster, grillwork, slatted or similar must consist of a top rail and midrail; the midrail should be positioned approximately halfway between the top rail and the walking surface. See 1917.112(c)(2).

Under 1917.112(c)(3), what are the height requirements for guardrails installed before and after October 3, 1983?

Guardrails installed before October 3, 1983 must have a top surface at least 36 inches high; guardrails installed after that date must have a top surface 42 inches high, plus or minus 2 inches. These height requirements are in 1917.112(c)(3).

Under 1917.112(c)(4), what is the maximum allowed sag for non-rigid railings like chain or wire rope?

Non-rigid railings such as chain or wire rope must not sag more than 6 inches at the midpoint between posts. This limit is specified in 1917.112(c)(4).

Under 1917.112(c)(5)–(6), what finishing and projection rules apply to guardrail top rails and ends?

Top rails must be free of puncture and laceration hazards, and rail ends must not overhang in a way that constitutes a hazard (scrollwork and non-hazardous boxed ends are allowed). These condition requirements are set out in 1917.112(c)(5) and 1917.112(c)(6).

Under 1917.112(d), when are toeboards required and what are their minimum specifications?

Toeboards are required when employees below could be exposed to falling objects; they must be at least 3½ inches high from top edge to floor and able to withstand a 50-pound force applied in any direction — drainage clearance under toeboards is permitted. See 1917.112(d).

Under 1917.112(e) and subsections, what are the strength and height requirements for stair railings and how many rails are needed based on stair width?

Stair railings must withstand at least a 200-pound force applied in any direction and be between 32 and 36 inches in height measured from the upper top rail surface to the tread surface. For stairways: less than 44 inches wide needs at least one railing; 44–88 inches wide needs railings or handrails on each side; 88 inches or wider requires an additional intermediate handrail. These requirements are in 1917.112(e) and its subsections 1917.112(e)(1) and 1917.112(e)(2).

Under 1917.112(f), what maintenance condition is required for railings?

Railings must be maintained free of sharp edges and kept in good repair. See 1917.112(f).

Under 1917.112, can guardrails be omitted at loading docks where cargo is handled?

Yes — 1917.112(b)(2)(i) and (ii) expressly state that guardrails are not required at loading platforms and docks or at waterside edges used for cargo handling. However, where omitting guardrails creates a fall hazard for workers, employers should provide other protections consistent with the standard and good practice.

If a marine facility is a 'designated waterfront facility' used solely for bulk storage and transfer of liquids or gases, does Part 1917 (including 1917.112) apply there?

No — Part 1917 does not apply to a designated waterfront facility used solely for bulk storage, handling, and transfer of liquids or gases; OSHA clarified this in a Letter of Interpretation. See the Letter of Interpretation on Applicability to waterfront facilities and consult 1917.112 for the standard’s scope.

When guardrails are impracticable under 1917.112(b)(3), is using safety nets an acceptable alternative?

Yes — where guardrails are impracticable due to machinery requirements or work processes, employers must use alternate means of protecting employees from falling, such as nets. This alternate means requirement is in 1917.112(b)(3).

Under 1917.112(c)(4), how should I inspect a chain or wire‑rope guardrail for compliance with the sag limit?

Measure the sag at the midpoint between posts — it must not exceed 6 inches. 1917.112(c)(4) requires this maximum sag for non-rigid railings such as chains or wire rope; routinely check tension and post spacing to maintain compliance.

Does 1917.112 require top rails to be free of puncture or laceration hazards, and what should I do if a top rail has sharp edges?

Yes — top rails shall be free of puncture and laceration hazards. If a top rail has sharp edges, it must be repaired or replaced so it meets that condition. See 1917.112(c)(5) and the general maintenance requirement in 1917.112(f).

Under 1917.112(d), can toeboards have drainage clearance underneath them?

Yes — drainage clearance under toeboards is permitted, provided the toeboards still meet the height (at least 3½ inches) and strength (withstand 50 pounds) requirements. See 1917.112(d).

If a stairway in a marine terminal has five risers and is 40 inches wide, how many railings does 1917.112 require and what height should the railing be?

A stairway with four or more risers requires railings or midrails; since the stairway is less than 44 inches wide, at least one railing is required. The railing height must be between 32 and 36 inches measured from the upper top rail surface to the tread surface in line with the leading edge of the tread. See 1917.112(e) and 1917.112(e)(1).

Under 1917.112(c)(1) and (e), do guardrails and stair railings share the same strength requirement?

Yes — both guardrails and stair railings must be capable of withstanding a force of at least 200 pounds applied in any direction. This is specified in 1917.112(c)(1) for guardrails and in 1917.112(e) for stair railings.

Under 1917.112, are stair railings required on short stairways with fewer than four risers?

No — 1917.112(e) requires railings and midrails for stairways having four or more risers; stairways with fewer than four risers are not covered by that specific railing requirement, though other safety measures may still be appropriate.