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Fixed-ladder rung spacing and variance request

Summary A food company sought a variance because the first step of several fixed ladders would vary in height while the remaining rungs were spaced 12 inches apart. OSHA said the arrangement met the rule's uniform-spacing intent and required no variance. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1975-03-20
Date issued
March 20, 1975
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Fixed Ladders Variances
Source
View the official document

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

March 20, 1975

Mr. Raymond F. Pusezan
Senior Staff Engineer
The Quaker Oats Company
[Recipient address omitted]
Dear Mr. Pusezan:

Assistant Secretary John H. Stender has asked me to respond to your letter dated March 10, 1975, requesting a variance from Section 1910.27(b)(1)(ii) Fixed Ladders - Rungs and Cleats, of the Occupational Safety and Health Standards.

Our technical staff has carefully reviewed your application. It has been determined that you are meeting the intent of the standard which is to provide a uniform clear distance of 12" equally spaced between rungs of your ladders on the described project.

You have stated that your first step will vary from 4" to 12" above the concrete slab at grade or above the lower platform landing. You have further stated, that the top of the ladder and the center line of the top rung would be at the same elevation. All other rungs on your fixed ladders will be equally spaced at 12". It would appear that you are providing uniform spacing of rungs for the user of the ladders.

The intent of this standard is to eliminate a continuing change of the uniform distance between rungs. This is not the case in your situation. Therefore, a variance is unnecessary.

No further action will be taken on your variance application.

Sincerely

Barry J. White
Associate Assistant Secretary for
Regional Programs

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