This letter clarifies OSHA's enforcement position on handrail and stair rail heights under the general industry walking-working surfaces rule, 29 CFR 1910.29(f)(1)(ii)(B) and 1910.29(f)(1)(iii)(A), which caused confusion after the 2017 rule update.
The dividing line is the installation date. For stair rail systems installed before January 17, 2017, the top rail may serve as the handrail when it measures 36 to 38 inches in height at the leading edge of the stair tread. For systems installed on or after January 17, 2017, the top rail and handrail must be separate components: the top rail must be at least 42 inches high, while the handrail must measure 30 to 38 inches.
Importantly for employers with existing stairs, OSHA stated it will refrain from issuing citations for systems that meet either configuration until a Federal Register Notice clarifies the standards' intent. Systems complying with either specification will be deemed compliant without requiring retrofitting.