How are federal OSHA and Cal OSHA fall protection similar? How are they different? For that matter, what is Cal OSHA? When it comes to guardrail fall protection standards, how do federal OSHA and Cal OSHA fall protection compare? This blog post aims to address these questions.
Federal vs State OSHA Overview
First of all, the Occupational Safety and Health Administration (OSHA) is an agency of the United States Department of Labor. Established in late 1970, the federal OSHA agency creates and enforces regulations, conducts inspections, and provides educational information. OSHA’s purpose is to ensure safe working conditions. People may have heard of OSHA and think of it as one organization with a single set of regulations. But it’s interesting to note that in addition to federal OSHA, there are states with their own health and safety regulations.
As of this writing, per OSHA: “State plans are OSHA-approved workplace safety and health programs operated by individual states or U.S. territories. There are currently 22 State Plans covering both private sector and state and local government workers, and there are six State Plans covering only state and local government workers.”
OSHA standards apply in each state and territory. Under federal law, OSHA may give a state the authority to administer their own health and safety programs. According to OSHA, state plans must be “at least as effective as OSHA in protecting workers and preventing work-related injuries, illnesses and deaths”. As a result, states may go above and beyond federal requirements. State plans may include hazards not addressed by federal OSHA. A state’s OSH program undergoes federal OSHA approval, and the federal government monitors and evaluates state approved plans.
State plans are not operated or enforced by federal OSHA. In fact, states which have their own OSH plans oversee their own programs. States which administer their own plan operate occupational safety and health training and education programs, conduct inspections to enforce the standards, and cover state and local government workers.
What is Cal OSHA?
Cal OSHA is California’s state health and safety plan for protecting the health and safety of workers in California. Approved by OSHA in 1973, Cal OSHA is one of the 22 state plans covering private sector and state and local government workers.
What is the difference between OSHA and Cal OSHA?
California’s state plan differs significantly from federal OSHA. In general, Cal OSHA fall protection standards are stricter than federal OSHA standards. California’s state plan also includes some requirements that federal OSHA does not include. For example, California’s OSH has an Injury and Illness Prevention Program (IIPP) as well as a Heat Illness Prevention Program.
When it comes to guardrail protection, California’s OSH code is more stringent than federal OSHA regulations. Next, we compare federal OSHA and Cal OSHA on three aspects of guardrail regulations.
Guardrail Regulations: Federal OSHA Compared to Cal OSHA
Height of Top Rail
Federal OSHA 1910.29(b)(1): “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.”
Cal/OSHA Title 8, 3209(a): “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).
Consequently, according to federal OSHA, the height of the top rail can be between 39 inches and 45 inches; while California’s OSH allows railings to be 41 inches to 46 inches in height.
Federal OSHA 1910.29(b)(2)(i): “Midrails are installed at a height midway between the top edge of the guardrail system and the walking-working surface.”
Cal/OSHA Title 8, 3209(a) cont.: “The midrail shall be approximately halfway between the top rail and the floor, platform, runway, or ramp.”
As you can see, federal OSHA and California OSH have similar midrail guidelines.
Federal OSHA 1910.29(b)(3): “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.”
Both federal OSHA and Cal/OSHA requires this 200 pound concentrated load. In addition, there is also a live load regulation in Cal/OSHA Title 8, 3209(b): “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.”
Live loads are not as easily calculated as concentrated loads. Calculations for live loads involve the dimensions and layout of the guardrail and mathematics to make sure the rails bear the 20 pounds per linear foot required by California OSH.
Federal OSHA and California OSH have similarities and differences, including similarities and differences to guardrail fall protection standards. Compliance with these standards help to keep your workers safe. Are you looking for a guardrail system that meets both federal OSHA and Cal OSHA requirements? If so, reach out to our helpful EDGE Fall Protection team.