• Standard Number:

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.

September 4, 1974

Mr. Thomas L. Cairns
Sr. Industrial Specialist
Brown & Root, Inc.
P.O. Box 3
Houston, TX 77001

Dear Mr. Cairns:

I have received your request concerning 29 CFR 1910.27(d) in reference to the special requirements of cages on fixed ladders, and offer the following.

The "railing ladder guard" in question does not meet the requirements of the OSHA standards. The term "equivalent construction" as used in 29 CFR 1910.27(d)(1)(i) refers to the strength and size of the material and the method of fastening devices used in the fabrication of cages. To further substantiate this, 29 CFR 1910.27(d)(1)(ii) requires cages be provided on ladders of more than twenty (20) feet to a maximum unbroken length of thirty (30) feet. It also requires dimensions of the cages be in conformance with those illustrated in Figures D-8 and D-9.

In answer to your question regarding the applicability of Figure D-9 to thirty (30) foot straight ladders, the above statement concerning the requirements of 29 CFR 1910.27(d)(1)(ii) should verify that the illustration would apply to the maximum ladder length permissible with a cage.

For your information, I am enclosing 29 CFR 1905, which contains provisions for granting variances to methods and/or operations that do not comply with the OSHA standards but may, in fact, provide equivalent employee protection as required by minimum Federal regulations.

If I can be of further assistance, please let me know.


Associate Assistant Regional Director
for Technical Support