Moving beyond mere regulatory compliance, adherence to OSHA standards protects workers from deadly safety hazards and health risks at work. Topics. Section 18(b) of The Occupational Safety and Health Act of 1970, P. Submit manufacturers' product data for following items for approval: 1. Ship stair (ship ladder) means a stairway that is equipped with treads, stair rails, and open risers, and has a slope that is between 50 and 70 degrees from the. 7 mm) sphere. A stair with a single riser or with two risers and a tread is permitted at locations not required to be accessible by Chapter 11 where the risers and treads comply with Section 1011. OSHA catwalk stair requirements. 25 (c) (2) requires standard stairs to h ave a maximum riser height of 9. ) (f) Stairway platforms shall be no less than the width of. Stair Treads are common in residential, industrial, and architectural applications. Riser height – 9. • Handrails and Stair rails: A. In general, the standards require the following: When there is a break in elevation of 19 inches (48 cm) or more and no ramp, runway, embankment or personnel hoist is. 2635 5 Ribbed Bar Abrasive Stair Tread ST S B- SERIES TREAD NOSING WIDTH INSTALL B Bar aBrasive e extruded anchors d drilled holes s single Part c concrete Pour - short nose P steel Pan - short tiPPed nose l steel Pan - long nose a steel Pan. Tread depths must be the same between. Of course, you should also check the OSHA codes as well as local building codes when designing a ship ladder. R311. 2. These measurements are taken at the leading edge of the treads. the employer must develop and implement a fall protection plan that meets the requirements of 29 CFR 1926. 24, 1978; 49 FR 5321, Feb. Interior stairs shall have the upper approach and lower tread marked by a stripe providing clear visual contrast. 1050-1060) deal mainly with when and where ladders or stairs are required. The standard focuses on proactive safety management — meaning that OSHA expects employers to find and fix workplace hazards BEFORE they become an issue. 1 -2007, Safety Requirements for Workplace Walking/Working Surfaces and Their Access; Workplace, Floor, Wall and Roof Openings; Stairs and Guardrails Systems, the standard now states in Section 6. Rise height and tread width shall be uniform throughout any flight of stairs including any foundation structure used as one or more treads of the stairs. Read More: Differences in IBC and OSHA Requirements. 1051 and 1926. Curved or Beveled Nosing 1½” max. 25(f)(1) Have a series of treads includes at a slope a 50 to 70 degrees from the horizontal; 1910. 25 inches. OSHA 1910. 6). OSHA requirements are set by statute, standards and regulations. The regulations cited apply only to private employers and their employees, unless adopted by a State agency and applied to other groups such as public employees. but tread wear indicator bars or the penny test can help you ensure you’re above the minimum tread depth requirements. The treads are manufactured with heat. Department of Labor200 Constitution Avenue, NW, N-3101 Washington, DC 20210 Telephone (202) 693-1888 or fax to (202) 693-2498. Maximum rise of 7-3 / 4 ”- maximum difference among risers 3/8". com Nystrom. Portable Ladders. According to OSHA guidelines, the minimum dimension for landings is 22” wide by 30” deep; all stairs with four or more risers must have handrails and guardrails; variations in riser height or stair tread depth must not exceed . For complete information, see the moved sections table in. Handrail Distance From Wall 1-1/2" to 4-1/2". 5 inches (15. (2) Trim shall not reduce the required width by more than 3 1/2 inches. Tread width must be uniform. I had to comply with OSHA requirements when safety guys asked for it during a design for a platform at a. We hope you find this information helpful. 15. Height is measured from the leading edge of the stair tread to the top surface of the handrail. 1926. Standard bearing bar spacing (from center to center of bearing bars) is 1-3/16". The following requirements apply to stairways used temporarily during construction. Stair Width: A minimum 22″ wide stair. S. OSHA says exposure to these types of hazards pose a. This includes, but is not limited to, requirements related to: general structural design, fire-resistant construction, light, ventilation, sanitation, plumbing fixture clearances, minimum room area and ceiling. Work Zone Traffic Safety. This web page provides the OSHA standard number, title, and subpart for the requirements of stairways and ladders in construction. + Note that handrails or guards used for. Rise and tread measurements are dictated by the angle of the stairway rise. On November 18, 2016, OSHA published a final rule on Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) in the Federal Register ( 81 FR 82494 ). McNICHOLS® Grating Stair Treads are assembled with the very best quality and craftsmanship available. R311. Life Safety Code, or IFC-2009, International Fire Code (incorporated by reference, see § 1910. 121 (b) (1) Stairways shall conform to the minimum dimensions of Figure F-1; Spiral Stairway - Minimum Dimensions. 25(b)(5)(ii) and shown in figure D-7 is. OSHA req'mnts for stair loading. To enhance safety and minimize stair falls, the 2006 edition of the OBC introduced specific tolerances for the uniformity requirements for rise height and tread depth. Occupational Safety and Health Administration 200 Constitution Ave NW Washington, DC 20210 1-800-321-OSHA 1-800-321-6742. Riser height shall be from 6 to 7. An OSHA-approved state plan must have safety and health requirements at least as effective as those of Federal OSHA and must adopt comparable stateThe treads and risers must have uniform width, length and height. 7. Exit Stairway Enclosures. Handrail Height. To me, the more important safety issue is that the riser heights and tread depths be. Minimum tread depth of 9. The employer must ensure guardrail systems meet the following requirements: 1910. 3 COMPONENTS. ErectaStep. These regulations are crucial in safeguarding personnel and visitors, as well as avoiding costly penalties and lawsuits for non-compliance. Topics. 29 (f) (1) (ii) (B)) and the handrail must be 30 to 38 inches in height (§1910. Labor Day: A Celebration Of Hard Work. : Deck-Stair Layout 101 – Deck stair layout is simple, right? Probably right, unless it’s the first time you’ve tackled the task. OSHA requires railings on open sides of stairwells and a handrail on at least on the side, preferably the right side descending at 42″ high. IRC Stair Nosing Requirements. Spiral stairs must meet the vertical clearance requirements inLoad-capacity of 1,000 lbs. The riser height must be between 4″ and 7″ and the treads must be at least 11″ deep. Also, a commenter (Docket S-041, Ex. (d). The riser height shall be measured vertically between the nosings of adjacent treads or between the stairway landing and the adjacent tread. ) (f) Stairway platforms shall be no less than the width of. 1014. Before you start building, you must first learn the parts of deck stairs. Railings. 5, the minimum depth of the tread is 13 inches (330 mm) and not less than one handrail complying with Section 1014 is provided within 30 inches (762 mm) of the. 5 mm) tolerance could interfere with the rhythm of the stair user. Elevated catwalks should be provided access by a stairway. Finger clearance: Minimum clearance between aTraining Requirements by Standard ; Enforcement Back. - to “one stair rail system with handrail on each open side”. Section 1910. This is in response to your memorandum of March 18, 1975, concerning 1910. The nosing hides the seam between the riser and tread and is both for aesthetics and safety. Safe-T-Metal Safe-T-Metal Products have been leading in the field of abrasive castings for over 40 years. Step Guardrail Height: Unlike ADA guidelines, the guardrails in OSHA steps also act as handrails when the top edge of the guardrail is between 36 and 38 inches above the leading edge of the stair tread. Chapter 10 is subdivided into four main sections: general. Ladder rungs shall have a minimum inside width of at least 12 inches and shall project at least 3 inches from the wall behind the ladder. Advisory 505. 2. 5 inches, a minimum width of 26 inches, and a headroom clearance of 78 inches. For each flight of stairs with two open sides and a width of less than 44 inches, column 4 of Table D-2 should state. The stair tread depth code is defined in OSHA sections 1910. Openings in stair walking surfaces shall be a size that does not permit the passage of 1 / 2 -inch-diameter (12. 493S Safety Insert Tread. (Title 24, Part 2, Section 3305 (b). Code requires guardrail in residential structures be a minimum of 36 inches. Add the Treads. Riser Height and Tread Depth (IBC 1011. 21(a) the following language from OSHA's construction standard (29 CFR 1926. For example, stairs. Treads. The minimum recommended stair landing length is 36" (or a length and width sufficiently greater than the swing of the door if a wider door is present. For each flight of stairs with two open sides and a width of less than 44 inches, column 4 of Table D-2 should state. Stair Tread Depth Definition. Tread and Nosing. 2. 5, the minimum depth of the tread is 13 inches (330 mm) and not less than one handrail complying with Section 1014 is provided within 30 inches (762 mm) of the. 5 Stair treads and risers. Handrail height at stairs is required to be between 34”-38” high. ASAE S207. The measurement of 865 millimetres can be taken vertically anywhereSee Sections 1609 for wind design requirements and 1613 for earthquake design requirements. Stairways. The stair tread water code is defined in OSHA sections 1910. Subchapter 4. The means of egress protection requirements work in coordination with other sections of the code, such as protection of vertical openings (see Chapter 7), interior finish (see Chapter 8), fire suppression and detection systems (see Chapter 9) and numerous others, all having an impact on life safety. B. Go; Company; Gallery; Videos; Support; Careers; ErectaStep Sales 888. A nosing is not required where the tread depth is a minimum of 11 inches (279 mm). For Employers ; Worker Rights ; Workers Memorial ;. Under §1910. "One stair rail system with hand rail on each open side" is required. 25 – Stairways: 1910. This distance must be at least 10 inches. OSHA Enforcement ; Annual Inspection Data ; Topics Back. • Vertical clearance above any stair tread to an overhead obstruction shall be at least 7 feet measured from the leading edge of the tread. OSHA stairs require less treads, a shorter horizontal run, and less extra railing, allow for a shorter, steeper stair that can generally save companies. 21 the stairBasic requirements. ) Reply #2: Yes. RE: OSHA req'mnts for stair loading. Tread and Nosing. If the tip of the diving board or diving platform is located at a distance of WA (see Figure 804. 5 Stair treads or risers. If an obstacle is unavoidable, the clearance must be at least 24 inches, and a device. Variations in riser height alternatively tread breadth wants not be over ¼-inch (0. • Variations in riser height or stair tread depth must not exceed 1/4 inch in any stairway system, including any foundation structure used as one or more treads of1003. 10. 25(b)(2) Vertical clearance above any stair tread to any overhead obstruction is at least 6 feet, 8 inches (203 cm), as measured from the leading edge of the tread. ADA handrail height should be between 34 and 38 inches. Stairways. 2120. The following requirements apply to all stairways as indicated: (a) Stairways that will not be a permanent part of the structure on which construction work is being performed must have landings of not less than 30 inches (76 cm) in the direction of travel and extend at least 22 inches (56 cm) in width at every 12 feet (3. 851 (c) In a multistory building, when a stairwell is being used, it shall be properly illuminated by either natural or artificial means, and completely. Associated work found in Division 5, "Metals,"Note: To determine contractor requirements, or to check the licensing status of a contractor, please call the Minnesota Department of Labor & Industry at 651-284-5065 or toll free 1-800-342-5354. This allowance provides some design flexibility. website at or contact the OSHA Publications Office U. 5” . Visual contrast on tread nosings or the leading edges of treads is helpful for people with low vision but not required by the ADA Standards. Stairs with winders need to be at least 11″ deep and when 12″ in from the narrow edge and the minimum depth must be 10″. The employer must ensure: (1) Handrails, stair rail systems, and guardrail systems are provided in accordance with § 1910. • Handrails and Stair rails: A. A nosing is not required where the tread depth is a minimum of 11 inches (279 mm). 2 allows access to unoccupied roofs to be a roof hatch or trap door. Standard 36" or 48" wide treads, 41 1/4" or 53 1/4". 1918. Created with funding by: A U. Stair Width – OSHA stair tread requirements 90 Railings and Guardrails – OSHA handrail requirements 390 | IBC handrail 320 Balusters – OSHA 1910. A - Optimal range: 30º-35º. 29(d)(1). A minimum radius of 0. 24 to 19. (d) has the appropriate toe boards and guardrails required by Part 22. Risers (the vertical element connecting treads) that are no less than 6 inches in height and no more than 7. 12, Point A shall be the point from which dimensions of width, length and depth are established for the minimum diving water envelope. 2 Treads. §1626. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Stair Tread Depth Definition. Stair treads and risers shall meet the requirements of this section. Railings. In 1988, the American National Standards Institute (ANSI), an organization which sets voluntary consensus standards, approved a revision of ANSI A10. (f) Alternating tread-type stairs. B. 25(f) beneath: 1910. The requirements of OSHA safety regulations for the safe use of ladders and stairs (Subpart X, Title 29 Code of Federal Regulations, Part 1926. A stair with a single riser or with two risers and a tread is permitted at locations not required to be accessible by Chapter 11 where the risers and treads comply with Section 1011. Stairwells and Stairs. The maximum variations in the height of risers or the width of treads in any one flight shall be one-fourth-inch. 851 (c) In a multistory building, when a stairwell is being used, it shall be properly illuminated by either natural or artificial means, and completely. the International Building Code or IBC sets the stair and handrail requirements for public buildings and public spaces. To meet OSHA requirements and maximize safety, ReadyStair solutions incorporate all the key components of industrial stair safety: Precision design and construction From degrees of riser height to tread width, OSHA has strict guidelines for. The following definitions apply in this subpart: Alternating tread-type stair means a type of stairway consisting of a series of treads that usually are attached to a center support in an alternating manner such that an employee typically does not have both feet on the same level while using the stairway. This letter constitutes OSHA's interpretation of the requirements discussed. Fixed Industrial Stairs: OSHA Standard 1910. 1-800-321-OSHA 1-800-321-6742 The maximum variations in the height of risers or the width of treads in any one flight shall be one-fourth-inch. OSHA requirements are set by statute, standards, and regulations. Many construction employees work at six feet or more above ground and need to be protected from slip-and-fall hazards. Standard Number: 1910. The height of stair rail systems installed on or after January 17, 2017 is not less than 42 inches (107 cm) from the leading edge of the stair tread to the top surface of the top rail. 500(a)(1)): Exception: The provisions of this subpart do not apply when employees are making an inspection. 8 kPa (100. Maximum height is 38 inches. 25(b)(5)(ii) and shown in figure D-7 is perpendicular to the direction of. The riser height shall be measured vertically between the leading edges of adjacent treads. 1052(c)(7) 1926. The height of top rails, or equivalent guardrail system members, is 42 inches, +/- 3 inches, and may not exceed 45 inches above the walking. 2. Thank you for your interest in occupational safety and health. A stair rail may serve as a handrail only when the top surface of the top rail is between 36 and 38 inches from the. Extensions shall return to a wall, guard, or the landing surface, or shall be continuous to the handrail of an adjacent stair flight. (a) is strong enough to support the equipment and workers who may use it, (b) is at least 600 millimetres wide, (c) is wide enough to ensure the safe movement of equipment and workers, and. The maximum and minimum cross-sectional dimension should be 2. An OSHA catwalk serviced by a stairway is a type of stair landing. 3-414) on proposed part 1910 subpart D (Walking and Working Surfaces) stated:. Each type of safety grating walkways, and planks. All required handrails shall be continuous for the full length of the stairs from a point directly above the top riser. 25 (Fixed Industrial Stairs) listed below price table. 7. Stair Tread Nosing Overhang Code Requirements. The maximum vertical distance between treads (riser height) is the same 18 in. 88 cm) between vertical barriers, tread depth a minimum of 12±2 inches. Variations in stair height cannot exceed 1/4 inch. 1 Labeling. UNITED STATES DEPARTMENT OF LABOR. OSHA requirements are set by statute, standards, and regulations. We provide building stairway codes that specify the size and placement requirements for safe, accessible stairway landings & platforms. 04(3)(b)6. Maximum 7-3/4 inch stair riser height. oregon. 2. April 22, 1975. 23(e), Railing Specifications. Enclosed accessible space under stairs shall have walls, under stair surface and anySPS 321. 25(c)(1) Are installed at angles between 30 to 50 degrees from the horizontal;. Designers can also provide a concrete slab edge angle detail that allows for adjustment by the detailer when the stair detailing is underway. A brief description of the OSHA Consultation Program, which is available to assist employers, is also included at the end of this publication. Exit routes must meet the following design and construction requirements: 1910. Normal use by employees. 2 Ceiling Height. IBC also has the additional requirement of adding an intermediate landing on stairwells more than 12-feet high, as well as handrail extensions on the bottom. 16 cm) and 7 inches (17. Handrails must be 30” – 38” tall and. 3 METAL. (36″ wide areas served by less than 50 people) Railings & Guardrail: OSHA requires railings on open sides of stairwells and a handrail on at least on the side, preferably the right side descending at. 8. 1052(a)(1) which requires a minimum width of at least 22 inches. The stair riser code is up to 7. Handrail And Guard Code. Exterior stairs shall have the upper approach and all treads marked by a stripe providing clear visual contrast. 1. Also the maximum nosing radius cannot exceed 9/16 of an inch. In the 2016 rulemaking, OSHA had allowed the top rail of stair rail systems to serve as a handrail when two conditions were met: (1) The height of that stair rail system is not less than 36 inches and not more than 38 inches, as measured at the leading edge of the stair tread to the top surface of the top rail; and (2) the stair rail system was. Industrial stairs meeting the OSHA requirements of a 9. (ICC) includes the building code and fire code which address in detail the requirements for safety and slip resistance in stairs and means of egress as already discussed. The nosing on treads, believe it or not, has a code minimum and maximum of how far the nosing projects over the next stair. 25(f)(2) Have an distance between handrails of 17 to 24 inches (51 to 61 cm); OSHA stairs are required to be a minimum of 22 inches wide. You have requested an interpretation of 29 CFR 1910. If the handrail isn’t circular, the perimeter dimension should not be less than 4 inches and mustn’t be greater than 6. This totals . IBC Stairs require guardrails of 42″ high and handrails of 34″ high on both sides of the stairwell. (7) Where the rise would exceed 9 1/2 inches and the run would be less than 8 inches, portable, fixed, or ships ladders shall be used. (a) General. Outdoor stair treads must comply with all the general stair tread requirements found in IRC section R311. The IRC requires a minimum stair tread depth of 10 inches (254 mm) with a nosing projection of between ¾ and 1 ¼ inches (19-32 mm). Treads shall be 11 inches (280 mm) deep minimum. Recommendation: Providing visual contrast (light-on-dark or dark-on-light) on the top and bottom steps that is approximately 2 inches wide and located either on nosings or at the leading edges of treads is helpful for people with low vision. 5 inches (24 cm) following OSHA 1910. Vertical rise between treads is generally around 9". It offers an attractive appearance while enhancing pedestrian safety. 1910. As well as choosing the right stairs for your application it is also important to keep up to date with legislation changes. S. 04. 4. A stair with a single riser or with two risers and a tread is permitted at locations not required to be accessible by Chapter 11 where the risers and treads comply with Section 1011. 25(b)(5)(ii) and shown in. Enforcement. 1053 (a) (1) (i) Each self-supporting portable ladder: At least four times the maximum intended load, except that each extra-heavy-duty type 1A metal or plastic ladder shall sustain at least 3. 17 cubic yards. The International Building code seemed to say that a rail would only be required if more than four (4) treads, but I want to comply with codes and safety rules. Open risers are permitted, provided that the opening between treads does not permit the passage of a 4-inch diameter sphere. At the top of a stair flight, handrails shall extend horizontally above the landing for 12 inches (305 mm) minimum beginning directly above the first riser nosing. These regulations are crucial in safeguarding personnel and visitors, as well as avoiding costly penalties and lawsuits for non-compliance. Note: For specific code requirements, contact the Building Inspection Department at 952-442-7520 or 888-446-1801 or e-mail: info@mnspect. it is important to ensure that the OSHA criterion is also referenced in the performance requirements for stair design in the project specifications. 01 inches is required for the edges. 4-1979 - Safety Requirements for Job-Made Ladders. STAIRMASTER anti-slip renovation treads are ideal for exit path markings, safety egress systems, steps and landings. It includes specifications for landings, risers,. The minimum load capacity must be at least 100 pounds per square foot, with a minimum tread center concentrated load of at least 300 pounds. The uniformity of risers and treads is a safety factor in any flight of stairs. Angled Riser 30° max. OSHA set the design requirements for alternating tread stairs included teil 1910. Jan 31, 2013. 878. 02 SUBMITTALS A. The tread depth code for residential stairs. The width of ship ladders is usually 24" and the tread depth is 6". Swing gate fall protection. Enforcement. §1626. c. OSHA stair requirements vs IBC stair requirement Stair components and stair types definitions Applications for different types of steep stairs Stair and handrail. The final rule defines ship stairs as “a stairway that is equipped with treads, stair rails, and open risers. Stair tread depths shall be 11 inches (279 mm) minimum. Tread: The part of the stairway that is stepped on. The two types of stairs are differentiated by a range of factors all related to their construction and measurement. 25 (Fixed Industrial Stairs) listed below price table. Ramps are covered under OSHA guidelines 1926. The means of egress protection requirements work in coordination with other sections of the code, such as protection of vertical openings (see Chapter 7), interior finish (see Chapter 8), fire suppression and detection systems (see Chapter 9) and numerous others, all having an impact on life safety. This is measured from the tip of the stair nosing. Both OSHA and IBC require landings at the top and bottom of the stairs, although IBC landings are. Stair treads must sustain a weight of at least. on the front five inches of the span at the center. 25”) and 355 mm (14”), between successive steps; rise: between 125 mm (5”) and 200 mm (7-7/8”), between successive treads; landing: less than 4. OSHA Stair Requirements. 5 inches. Compliance with OSHA Requirements. Lack of B. OSHA Stair Requirements. Safety grating walkways, planks and grating beneath acess covers. Among the requirements is the minimum stair width. 1910. IBC Stairs require guardrails of 42″ high and handrails of 34″ high on both sides of the stairwell. Since that time, OSHA has received many questions and requests for interpretation of the requirements for handrails and stair rail systems. It is important to note, however, that while these codes apply in the majority of states in the U. Occupational Safety and Health Administration 200 Constitution Ave NW Washington, DC 20210 1-800-321-OSHA 1-800-321-6742. 6] Thank you for your March 3, 2000 letter to the Occupational Safety and Health Administration's (OSHA's) [Directorate of Enforcement Programs (DEP)]. Vertical rise – 30° to 50°. 2 stipulates that the minimum and maximum stair riser heights must be 4 inches (10. For the purposes of this section, dimensions and dimensioned surfaces shall be exclusive of carpets, rugs or runners. The railings must be capable of withstanding a force of at least 200 pounds applied in. 28 (b) (11) (ii) Table D-2 contains a printing error, which OSHA will correct in a published notice. The tread depth shall not be. The Code identifies minimum and maximum requirements for both and is commonly adopted by. 1910. Ends shall be returned or terminated in newel posts or safety terminals. If a stairway accesses the catwalk, the width requirements depend on the width of the stairway that serves it. 451(m)) and proposed (1926. 5 inches. "One stair rail system with hand rail on each open side" is required. OSHA standards or the Occupational Safety and Health Act of 1970. yright 2012 SAOSHA is requesting updates to the handrail and stair rail system requirements for its general industry, Walking-Working Surfaces standard, according to a press release. 2. Fixed stairs are in compliance with the standard if the rise and tread run dimensions produce a stairway with an angle to horizontal between 30 and 50 degrees. Treads with open risers or treads deeper than 11 inches do not require nosings. ¯W” j [)Ù·ïXŠ»¦1¬ Û€a4:ü’> 4æ €«A"H-@Y°œƒ¶€h4 ¨ ÆZ” ¹ ŽBÁÝ »oε Ë> Ÿ»½ mh £!…Þ’hot4&ö!I2 ¶{99–—_]·Z ÕÚ»Úw z±MÛœO}uÁ Ü c嶛5+Ø®-ëîT¶®®^¢Bè¸Z±OîùX®›Ë>¡ñ 9˜” HŸºzàAsëºæÜV®#Ý ¿)|é •7 GÚ]œ·0 H’ -‰š3 Ú2 6. 24 (e), if they have a rise of 7. REDD Team will help you meet OSHA standards for stairs and put fall-protection safeguards in place at your job sites. Treads must be slip-resistant with nonslip nosings. Also, the exception to IBC 1011. This letter constitutes OSHA's interpretation of the requirements discussed. These stairs must have a 22-inch wide and 30-inch deep landing for every 12 feet of vertical rise and be set at an angle between 30 and 50 degrees from the horizontal. 2. DRAWING 8. Like the IBC, OSHA dictates specific measurements. Occupational Safety and Health Administration 200 Constitution Ave NW Washington, DC 20210 1-800-321-OSHA 1-800-321-6742 Federal. (a) Application of requirements. 75 inches, and can not vary more than 3/8 of an inch. For example, stairs manufactured with a 45-degree stairway rise must have a minimum rise and tread of 8. and a vertical clearance above any stair tread to any overhead obstruction of at least 6 feet 8 inches.