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OSHA INSTRUCTION STD 1-15.4 OCTOBER 30, 1978
OSHA PROGRAM DIRECTIVE #100-46
TO: REGIONAL ADMINISTRATORS - OSHA
Subject: Interpretation of 29 CFR 1910.268(h)(8) Ladders Requirements
Applying to Metal Manhole Ladders
1. Purpose
To provide specific interpretation as to the intent of the
application of 29 CFR 1910.268(h)(8)(i), (ii), (iii), (iv), (v), and
(vi).
2. Directive Affected
None.
3. Background
a. The intent of the proposed and final standard at 29 CFR
1910.268(h)(8), Metal Manhole Ladders, published in the Federal Register on
August 28, 1973, and March 26, 1975, respectively, was to limit its scope to
"portable metal manhole ladders.
b. This intent is evident when Section 1910.268 (h)(8) is compared
to 29 CFR 1910.26 - the General Industry standard which applies to portable
metal ladders. The language of section 1910.26 is virtually identical to
that contained in Section 1910.268(h)(8). Moreover, the language of Section
1910.268(h)(8) is inconsistent with 29 CFR 1910.27 - the General Industry
standard which applies to fixed ladders.
4. Action
The enforcement of 29 CFR 1910.268(h)(8)(i) through (vi) as written
shall be limited to "portable" metal manhole ladders used in the
telecommunication industry. Fixed manhole ladders are not covered by 29 CFR
1910.268(h)(8).
OSHA INSTRUCTION STD 1.15.4 OCTOBER 30, 1978
5. Effective-Date
This directive is effective immediately and shall remain in effect
until canceled or superseded.
Barry J. White Associate Assistant Secretary for Regional Programs
Distribution: A-1 B-2 C-1 D-4 & 5 Training Center
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