August 3, 1992
MEMORANDUM FOR: JOHN B. MILES, JR.
LEO CAREY, DIRECTOR OFFICE OF FIELD
FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Specialty Ladders Used in Manholes
This is in response to your March 3 memorandum requesting an interpretation
as to whether or not ladders, designed to be used in manhole applications,
must comply with the OSHA's construction and general industry side rail width
requirements. I apologize for the delay in responding to your inquiry.
In his February 5 letter to you, Mr. Kline of Lynn Ladder and Scaffolding
Company stated that a ladder meeting the width requirements of Subpart X will
not offer safe access into 24-inch diameter manholes. In order for us to
make a determination that compliance with this standard is unsafe, more
information is needed. Please provide to us an analysis or clearance
comparison of the two different width ladders when used to access 24-inch
If we can be of any further assistance, please contact Mr. Rolland Stroup in
the Office of General Industry Compliance Assistance on (202) 523-8031 or Mr.
Dale Cavanaugh in the Office of Construction and Maritime Compliance
Assistance on (202) 523- 8124.