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Fixed ladders for periodic tower maintenance

Summary A company asked whether a tower with two equipment platforms could use fixed ladders. OSHA said ladders meeting the fixed-ladder design rule appeared acceptable if employees used them only for periodic or monthly maintenance and no daily work occurred there. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1978-11-17
Date issued
November 17, 1978
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Platform Access
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

November 17, 1978

Mr. N. Ray Warmack
Gaido - Lingle Company, Inc.
[Recipient address omitted]
Dear Mr. Warmack:

This is in response to your letter dated November 7, 1978, requesting a clarification of 29 CFR 1910.24(b). Your letter was forwarded to this office for response.

The subject tower 18.5 feet in height from the floor level with two platforms which contain the receiving tank, vacuum drive air filter and exhaust systems may be equipped with fixed ladders meeting the design requirements of 29 CFR 1910.27 provided:

  1. There is no daily work activity required.

  2. The fixed ladders are used to provide periodic or monthly maintenance for the equipment on the platforms.

Recognizing the limited work exposure to employees as indicated above it appears that a fixed ladder complying with 29 CFR 1910.27 satisfies the requirements.

If I may be of any further assistance, please feel free to contact me.

Sincerely,

John K. Barto, Chief
Division of Occupational
Safety Programming

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