Archived fixed-ladder side-rail gripping interpretation

August 8, 2005

Mr. Richard A. Eichel, CSP

ATA Safety & Health Group

[Recipient address omitted]

Dear Mr. Eichel:

Thank you for your February 15, 2005 letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs (DEP). Your letter has been referred to DEP's Office of General Industry Enforcement for an answer to your question regarding OSHA's fixed ladder standard, 29 CFR 1910.27. It is my understanding that your staff has discussed your letter with my staff and your question has been restated below for clarity.

Scenario: Several "step through" type fixed ladders (between 8 and 24 feet in height) are constructed using two-inch angle iron as side rails. The angle iron side rails are cut about one inch above the top rung. The top two rungs extend out past the ladders side rails and one-inch pipe has been welded to these extensions. The pipe then extends up the required three and one-half feet at a width of 24 inches and is bent over at the top to create handholds.

Question: Do the side rails on these ladders meet OSHA's fixed ladder standard?

Reply: 29 CFR 1910.27(b)(2) requires that side rails which might be used as a climbing aid be of such cross sections as to afford adequate gripping surface without sharp edges, splinters, or burns. It does not appear from the information provided that the two inch angle iron would afford an adequate gripping surface.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain the requirements, and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. In addition, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director

Directorate of Enforcement Programs