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.

June 23, 1977

Mr. Lawrence R. Stafford, P. E.
8 Gracemore Street
Albany, New York 12203

Dear Mr. Stafford:

This is in response to your correspondence of April 14, 1977, addressed to Alfred Barden, Regional Administrator, Occupational Safety and Health Administration (OSHA), regarding the use of structural steel angles for cleats on fixed ladders.

This office has reviewed your sketch, dated April 12, 1977, and your letter. The 1 3/4 inches by 1 3/4 inches by 3/16 inch angles that you intend to use as cleats on the fixed ladder do not meet the definition of cleats as used in 29 CFR 1910.27 Fixed Ladders. As the second paragraph in your letter so noted, "Cleats are ladder cross pieces of rectangular cross-section placed on edge on which a person may step in ascending or descending." A steel angle does not have a rectangular cross-section.

In addition, your 1 3/4 inches by 1 3/4 inches metal surface design may induce hand slippage when the employee is ascending or descending the ladder.

Thank you for your concern and continued interest in safety and health.

Sincerely,



John K. Barto,
Chief
Division of Occupational Safety Programming