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Individual steps in manhole risers

Summary An engineering firm asked whether OSHA's fixed ladder rule applied to individual steps in manhole risers and conical top sections. OSHA said it did not, pointed to a separate instruction, and noted that the instruction assumed the steps were directly aligned. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1980-12-02
Date issued
December 2, 1980
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Manhole Steps Fixed Ladders 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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

December 2, 1980

Mr. James Mohart
Black & Veatch
[Recipient address omitted]

Dear Mr. Mohart:

This is in response to your recent letter requesting clarification of our requirements for manhole steps in walls of risers or conical top sections of manholes. This also confirms a telephone conversation with a member of my staff, Mr. Simms.

As indicated in our program directive, 29 CFR 1910.27 does not apply to individual steps in walls of risers or conical top sections of manholes. OSHA Instruction STD 1-1.9 provides the applicable requirements in this matter, and direct alignment of individual rung or steps in manholes was assumed.

The Directorate of Safety Standards Programs has not been petitioned to develop standards permitting individual steps in manholes to be installed with a staggered alignment.

If we may be of any further assistance, please feel free to call or write.

Sincerely,

John K. Barto
Chief, Division of
Occupational Safety Programming

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