Pivoting ladder at an emergency exit elevation change

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 12, 1975
Mr. LaVern W. Cass
Corporate Safety Director
Northern Engraving Company
Luxco Incorporated
[Recipient address omitted]
Dear Mr. Cass:
This is in response to your letter dated July 24, 1975, which supplied additional information relative to your request for variance from Section [1910.37(a)(3)] ~~Means of Egress - Changes in Elevation,~~ of the Occupational Safety and Health Standards.
[This document was edited on 02/05/2004 to strike information that no longer reflects current OSHA policy. 29 CFR 1910 Subpart E was revised on November 7, 2002. This section is now titled "Exit Routes - Maintenance, safeguards, and operational features for exit routes.]
Your request for a variance from the means of egress guarding requirements of the above standard has been carefully evaluated by our technical staff and we have concluded that a variance is not required.
You have stated that a remote exit located in the Northwest corner of your building "B" has a 35" elevation change from plant floor to grade. This door is not used as a normal means of egress due to the presence of a railroad abutting the building. Although not required, this door could be used as an emergency exit.
The above standard requires that ["Stairs or a ramp must be provided where the exit route is not substantially level."] Your installation of the special purpose pivoting fixed ladder would appear to meet the intent of this standard. Therefore, a variance is not required.
No further action will be taken on your request for a variance from Section [1910.37(a)(3)].
Sincerely,
Barry J. White
Associate Assistant
Secretary for Regional Programs