- Standard Number:1910.27(d)(1)
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.
January 15, 1976
Mr. James J. Palacek
Schuld Manufacturing Company, Inc.
Mosinee, Wisconsin 54455
Dear Mr. Palacek:
This is in response to your letter (with enclosure) of November 20, 1975, addressed to Mr. Largent, Assistant Regional Administrator, Technical Support, of our Chicago Region, regarding cages on fixed ladders.
An Occupational Safety and Health Administration (OSHA) approval or disapproval of a product is not allowed by the Williams-Steiger Occupational Safety and Health Act of 1970.
This office has reviewed your Assembly Instructions Drawing Number A-20001 as requested, and finds that it agrees with the applicable requirements of Figure D-8 in 29 CFR 1910.27(d), with one exception. This exception is in the means of attaching the basket guard hoops and the vertical bars.
1910.27(d)(1)(i) gives the employer the choice of building the cage according to Figure D-8, if appropriate, or of equivalent construction. Your question of whether your bolted assembly is equivalent to riveting or welding has to be given a qualified answer. The Compliance Safety and Health Officer (CSHO) makes a determination at the time of the inspection as to whether the bolted basket guard hoops are equivalent to riveted or welded attachments. The CSHO would also determine if the inside of the cage is clear of projections. References 29 CFR 1910.27(d)(1)(v).
If I may be of any further assistance, please feel free to contact me.
John K. Barto, Chief
Division of Occupational