High Platform, No Railings (yes, this again)

Okay, so I know railings have been discussed before, but this situation is a little different than what I've found on the forums, and different than what I have dealt with myself in the past.

First, this is a college production where no performers are employees falling under OSHA jurisdiction. Shop employees will take appropriate measures.

The scenic designer has asked if he can have a staircase to an 8'x8' platform 8' high with no railings anywhere. I'm not making a final judgement in terms of my own/institutional safety and liability concerns until I know in detail how this space would be used, because I can imagine scenarios where I would allow it with plenty of rehearsal, spotters, and access control. My question is not about safety but purely about code issues.

This is Massachusetts, which uses IBC 2009 with amendments. Below is the portion of IBC that is usually referenced when someone wants to skip railings on set, specifically exceptions 2 and 3. My reading is that the platform itself could have no railings at all (exception 3) but the stairs leading to it do not fall under exception 3, which only mentions raised floor areas. The stairs could only claim exception 2, eliminating a downstage railing only. This is my inclination anyway, unless the stairs are very wide and traffic is restricted to the center.

Does this sound right? My experience with unguarded edges this high has so far been limited to the audience side. I've never had to rule on all edges being unguarded.

1013.1 Where required.Guards shall be located along open-sided walking surfaces, including mezzanines, equipment platforms, stairs, ramps and landings that are located more than 30 inches (762 mm) measured vertically to the floor or grade below at any point within 36 inches (914 mm) horizontally to the edge of the open side. Guards shall be adequate in strength and attachment in accordance with Section 1607.7.

Exception: Guards are not required for the following locations:
1. On the loading side of loading docks or piers.
2. On the audience side of stages and raised platforms, including steps leading up to the stage and raised platforms.
3. On raised stage and platform floor areas, such as runways, ramps and side stages used for entertainment or presentations.
4. At vertical openings in the performance area of stages and platforms.
5. At elevated walking surfaces appurtenant to stages and platforms for access to and utilization of special lighting or equipment.
6. Along vehicle service pits not accessible to the public.
7. In assembly seating where guards in accordance with Section 1028.14 are permitted and provided.

Colin said:

First, this is a college production where no performers are employees falling under OSHA jurisdiction.

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Bold Statement. Best practices for safety tend to fall back to ANSI and OSHA so even if someone is not explicitly covered by the statute if there is a legal case those standards could be used to judge adequate safety measures taken. Food for thought...

On to your actual question. In my understanding yes, this is the exact situation those exemptions exist for. It sounds like you have a good idea of what administrative controls (rehearsal, spotters, and access control) would be good practice to protect the actors in lieu of the engineering controls (the guard rail) so I won't dwell on it, but it's important. The hand railing on the upstage side of the stairs could be argued for in my mind, but your actors job already has the risk of an 8' fall from the unprotected edge of the platform. I find it hard to believe that the additional safety measures put in place to make the platform itself safe would all of the sudden become unacceptable once dealing with stairs. This would, however, mean that whatever "appropriate measures" shop employees use to keep themselves safe on the platform would have to start on the stairs.

I would consider screwing at least a toe kick around the edge, a simple 1x3 or smaller. Can work wonders for spacial awareness.

I cannot and will not comment regarding to the laws and codes, especially in your area.

I agree that a toe kick is a good idea if at all possible. Of course glow tape, etc is also useful for this. The idea of course is to make certain that the performer is always spatially aware of where the edges are at all times.
Stairs are inherently more dangerous than the platform, people trip up and down or drift to the edge all the time. Id always shoot for stairs over a few steps to have at least one side with support for someone to grab a hold of in case they trip, etc. I am much more likely to allow a platform with no guards than stairs.

Typically I try and put a railing along the upstage side at least as due diligence and safety. Other methods can be used to keep people from plummeting from the other edges such as you mentioned.

If you are truly concerned I'd try and contact your local jurisdiction and see what they have to say (and be nice and discreet; if you are not nice they won't be inclined to co-operate).

I guess you could always do some sort of "safety assessment" of the desired set, listing your various controls and such along with how you plan to mitigate the risk. Such forward thinking in a document is always good for peace-of-mind. Again I do not comment regarding the legality therein. I am not familiar with rules and laws and codes (and such legalities) where you are.

Technically any time working at height a risk assessment is a good idea. In a "First man up" situation there are no guards or lanyards some times until said "first man up" can install them. Mitigating the risk and having an action plan is the name of the game.

SAFETY IS ALWAYS IMPORTANT.

Thanks, everyone.

I tried to isolate the code aspect in my question because I am confident in my understanding and management of the safety hazards, but I'm fine with dwelling on the safety side here in an online forum. I don't want anyone researching this in the future to get the impression that just because the applicable code says it is allowable that means it is a good idea without lots of planning and care.

It sounds like the designer is now leaning towards an upstage wall, which could help a lot as something safe to anchor the action near.

I don't have all the details yet, so this is not a go as of now. Once I have his draft of the stairs and platform we will devote a production meeting to establishing the desired use (which will be non-negotiable if/when I give the go ahead). If I am satisfied with that I'll do a written hazard assessment and plan for surface and edge finishes, allowable proximity of performer to edge (before the spotter in the wing sounds a warning), minimum light level, costume considerations (i.e. no floor length skirts/robes, high heels...) rehearsal and performance requirements (spotter for rehearsals in the taped out rehearsal space, and probably a fight call type situation once they get on set) and access control and signage.

I like a toe kick for situations like band risers where a stool or chair could get backed off the edge. When it is just people stepping near the edge though, I get concerned that it only becomes a tripping hazard that could keep someone from righting themselves if they do find themselves teetering on the edge. Contrasting tape (at least partly glow just in case, although I don't like the idea of anyone moving in blackout in this situation) is more likely where I'll go. Possibly a "warning track" some distance in from the edge too, perhaps of a textured anti-slip tape although that surface change can again become a trip hazard.

I have always been led to believe that stage sets with performers on them were not bound by rules of railings under OSHA or other agencies that govern safety practices. By exempting these temporary scenic structures when used by performers it allows the artistic expression to be fully actualized for a show. If every set we designed or built had to meet the standards set by OSHA/ANSI for even temporary structures things would look much different onstage and our hands would be tied pretty tight.

Now that being said safety has to be a consideration. How is the platform used? Is it accessed in the dark? by children? Does it have 8 people dancing on it? It is our job as technicians to make our stage spaces as safe as possible and to point out deficiencies where design and safety collide (in my opinion). All the suggestions for toe kicks and glow tape are for sure great ways to begin to mitigate this risk but a tall platform with no railings is always a fall hazard. Responsibly if I were the TD on this I would identify it as such then mitigate where I could and suggest options to make it safer prior to building it as the artistic staff requests. If you feel it crosses the line then don't.

Mark Hanneman said:

I have always been led to believe that stage sets with performers on them were not bound by rules of railings under OSHA or other agencies that govern safety practices. By exempting these temporary scenic structures when used by performers it allows the artistic expression to be fully actualized for a show. If every set we designed or built had to meet the standards set by OSHA/ANSI for even temporary structures things would look much different onstage and our hands would be tied pretty tight.

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In a word, false. People working, be they technical staff or performers, have a right (enforced in the US by OSHA) for that work space to be the safest it can reasonably be. It is possible that the job people working in that space are doing can require them to be subjected to a hazard that would normally be completely protected against, but that is for a specific person fulfilling a specific job that cannot reasonably be done with complete safety precautions in place.
A relevant example is that actors can perform on elevated platforms without protected edges. Their job is the performance, and that performance requires the elevated risk. You still must do whatever you can to reduce their risk of injury (as noted minimum light levels, costume considerations, spotters, etc...).
A very important and often overlooked note here is that just because one person's job requires them to subject themselves to this elevated risk DOES NOT mean that everyone working on the site can be subjected to that risk. This means that people that don't need to be on the platform unprotected to do their job (i.e. anyone who's not one of the actors in the scene) needs to have additional measures to protect them. Translated, actors not in that scene can't go up onto the platform (access control). If anyone else needs to go up onto the platform they need to have some kind of additional fall prevention. This absolutely does mean that in order to have everyone as safe as reasonable you could have the actor with no fall protection standing next to a technician with fall protection on the platform at the same time. Yes that seems weird. Hooray strange safety situations.

porkchop said:

In a word, false. People working, be they technical staff or performers, have a right (enforced in the US by OSHA) for that work space to be the safest it can reasonably be. It is possible that the job people working in that space are doing can require them to be subjected to a hazard that would normally be completely protected against, but that is for a specific person fulfilling a specific job that cannot reasonably be done with complete safety precautions in place.
A relevant example is that actors can perform on elevated platforms without protected edges. Their job is the performance, and that performance requires the elevated risk. You still must do whatever you can to reduce their risk of injury (as noted minimum light levels, costume considerations, spotters, etc...).
A very important and often overlooked note here is that just because one person's job requires them to subject themselves to this elevated risk DOES NOT mean that everyone working on the site can be subjected to that risk. This means that people that don't need to be on the platform unprotected to do their job (i.e. anyone who's not one of the actors in the scene) needs to have additional measures to protect them. Translated, actors not in that scene can't go up onto the platform (access control). If anyone else needs to go up onto the platform they need to have some kind of additional fall prevention. This absolutely does mean that in order to have everyone as safe as reasonable you could have the actor with no fall protection standing next to a technician with fall protection on the platform at the same time. Yes that seems weird. Hooray strange safety situations.

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Similar rules hold true for pyrotechnics. Per NFPA, performers can be closer to certain effects than the audience, but that doesn't mean controls shouldn't be tight and everyone can run around to their heart's content.

I think Actor's Equity has some requirements for railings that could give you another source of information. You might want to check with them and see what they say. While I believe that OSHA does not necessarily apply to volunteers or students, I think that no matter who falls off the platform or ladder, they get hurt the same.