Fixed ladders as emergency exits

November 27, 1978

L.C. Nicholas, P.E.
The H.K. Ferguson Company
[Recipient address omitted]
Dear Mr. Nicholas:

This is in response to your recent letter addressed to Mr. Donald Shay and confirms a telephone conversation with a member of my staff, Mr. William Simms, concerning [exit routes]. Your letter was referred to this office for response.

The Occupational Safety and Health Administration's general industry safety and health standards in 29 CFR [1910.36(g)(2)] requires that the minimum width of any way of exit access shall in no case be less than 28 inches. In addition, 29 CFR [1910.37(a)(3)] requires ["Stairs or a ramp must be provided where the exit route is not substantially level"]. Employers unable to meet the [exit route] requirements may because of unusual circumstances apply for a variance in accord with Section 6 of the Act.

A fixed metal ladder meeting the design requirements of 29 CFR 1910.23 would not be acceptable for a second [exit route] (emergency exit).

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

Sincerely,

John K. Barto, Chief
Division of Occupational Safety Programming

[Corrected 2/6/2004 and 8/1/2023]