Key Differences Between Cal-

OSHA and Federal OSHA

Guardrails

California OSHA code (Cal-OSHA) is notorious for being more

stringent across the board on their requirements than federal
OSHA. Their fall protection requirements are no different. Because
of this, we here at Simplified are constantly asked, "This says it
meets OSHA, but what about Cal-OSHA?" This is a valid question.
However, it can be a difficult one to answer. One must first
understand what OSHA says about the topic. From there, knowing
what Cal-OSHA requires in addition or how it differs will help
determine what is truly needed.

For the sake of this post, we will focus on a few specific

requirements on guardrails for fall protection. Keep in mind, this is
not intended to indicate the standards for where the railing is
needed. If you still have questions on when and where railing is
necessary, you can find this information simply by downloading our
ebook.
What makes a guardrail compliant in general industry or not? Here
are a few items that OSHA 1910.29(b) mentions:
 "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)

 "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)

 "Guardrail systems are capable of withstanding, without failure,

a force of at least 200 pounds (890 N) 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)

This is certainly not an exhaustive list of all the specifics, there is no

better resource for that information than directly on OSHA’s website
under 1910.29(b). These are merely common aspects of a guardrail
that you will see across the board. In understanding these, you can
quickly determine if a railing is going to meet code.

Now, what does Cal-OSHA have to say about this? Again, here are
the equivalent standards in Cal-OSHA’s General Industry
Guardrailing Requirements:
 "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 8, 3209(a)

 "The midrail shall be approximately halfway between the top rail

and the floor, platform, runway, or ramp." - Title 8, 3209(a) cont.

 "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)

The fundamental differences here that should be pointed out are

the differences in allowable height and loading capacity. When
figuring out the tolerances for the OSHA guardrail height, the
minimum allowed is 39". Cal-OSHA’s 1” tolerance only allows for a
minimum height of 41”.

As for the load calculations, it is imperative to know that there is a

difference between a concentrated load and a live load. The 200 lb
concentrated load will be required on both Cal-OSHA and OSHA.
Determining the live load is much more complicated, as it deals with
the overall dimensions and layout of the railing. Calculations will
need to be done to conclude that all possible scenarios of loading
will not push the railing out of compliance.
Cal-OSHA does give a note here to say that under certain
circumstances, railing may need to be designed for additional
strength. These scenarios will not apply to everyone. If you have
any questions or concerns, it is best to work with a fall protection
expert when discussing your railing solution in California.

Always make sure that the railing you pick for your fall protection
has been tested to meet and exceed what is compliant. Remember,
OSHA and Cal-OSHA are giving a bare minimum of what would be
determined safe. Fortunately, railings such as KeeGuard, have
been third-party tested to surpass the minimum set by OSHA and
Cal-OSHA.
Anytime someone says railing is tested to OSHA, ask for the testing
documentation. This information should be readily available. It’s
peoples lives on the line.