|OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these 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. Also, 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 http://www.osha.gov.|
October 3, 1991
||PATRICIA K. CLARK, DIRECTOR|
DIRECTORATE OF COMPLIANCE PROGRAMS
||Width of Manhole Steps|
The Notice of Proposed Rulemaking on Walking and Working Surfaces and Personal Protective Equipment dated April 10, 1990, contains a proposed standard entitled 1910.24 Step Bolts and Manhole Steps (copy of page 13399 attached).
Manhole builders and contractors in more than one State have requested an interpretation from the OSHA National Office relative to the mandatory width of manhole steps. The proposed standard at 1910.24(b)(2) states that the minimum clear step width of manhole steps shall be 10 inches (25.4 cm). Also, the preamble to the proposed standard on pages 13369 and 13370 (copies attached) states that the only OSHA current standards related to manhole steps are located at 1910.268, and apply to telecommunications centers and installations.
In the absence of OSHA specifications to the contrary, until the final rule on Step Bolts and Manhole Steps is published and becomes effective, citations shall not be issues when manhole steps with a clear step width as short as 10 inches (25.4 cm) are encountered.
§1910.24 Step bolts and manhole steps.
- (a) Scope and application. This section covers step bolts and manhole steps used on structures such as, but not limited to, towers, stacks, conical manhole sections, and vaults. This section does not apply to individual rung ladders.
- (b) General requirements.
- (1) Step bolts and manhole steps shall be continuous and spaced uniformly, not less than six inches (15 cm) nor more than 18 inches (46 cm) apart.
- (2) The minimum clear step width of step bolts shall be four andone-half inches (14.4 cm). The minimum clear step width of manhole steps shall be 10 inches (25.4 cm).
- (3) The minimum toe clearance for manhole steps shall be four inches (11.1 cm) from the point of embedment on the wall to the outside face of the step. The toe clearance in the center of the manhole step shall be a minimum of four and one-half inches (11.4) cm) measured to the outside face of the step.
- (4) The minimum toe clearance for step bolts shall be seven inches (17.8 cm). Where obstructions cannot be avoided, toe clearances may be reduced to four and one-half inches (11.4 cm).
- (5) Step bolts and manhole steps shall be designed to prevent the employee's foot from slipping or sliding off the end of the step bolt or manhole step.
- (6) All manhole steps and step bolts installed after (insert date 60 days after the effective date of the final rule in the Federal Register) and used in corrosive environments, shall be constructed of, or coated with, a material that will retard corrosion of the step or bolt.
Note: On April 10, 1990 OSHA published proposed revisions to Walking and Working Surfaces; Personal Protective Equipment (Fall Protection Systems); Notices of Proposed Rulemaking; Slips; Falls;Trips in Federal Register 55:13360-13441. It is available electronically only as an abstract. On May 2, 2003 OSHA reopened the rulemaking record on the proposed revisions to Walking and Working Surfaces and Personal Protective Equipment (Fall Protection Systems). It was re-published in its entirety in Federal Register 68:23527-23568 and is available electronically.]