Horizontal rails are only banned as climbable where the fall is more than 4 m.
Climbable means something specific. The ban on horizontal elements between 150 and 760 mm applies where the fall is more than 4 m, measured to the surface beneath. At 3 m the deemed-to-satisfy rule does not bite. What does still apply is the 125 mm opening and the 40 mm edge gap, and a solid bottom panel is not a defined fix. Argue the right point.
The answer. Not at 3 m, on the deemed-to-satisfy rules: the ban on climbable horizontal elements between 150 mm and 760 mm above the floor only applies where the fall is more than 4 m, measured to the surface beneath. The 125 mm opening and 40 mm edge gap rules still apply, and a solid bottom panel is not a defined fix in the Standard.
ABCB Housing Provisions Standard (NCC 2022), 11.3.3(1) Barriers to prevent falls, p. 301
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