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 https://www.osha.gov.

December 4, 1978

Mr. James T. Tester
Layout Draftsman
Envirotech - Buell
200 North Seventh Street
Lebanon, Pennsylvania 17042

Dear Mr. Tester:

This is in response to your letter dated November 21, 1978, requesting information on fixed ladders and cages.

The general industry safety and health standards for fixed ladders and cages specifically 29 CFR 1910.27(d)(1)(i) requires cages or wells (except on chimney ladders) to be built, as shown on the applicable drawings, covered in detail in figures D-7, D-8, and D-9, or of equivalent construction. Although your four sketches of safety cages do not meet the exact details of the above mentioned figures, they appear to provide equivalent construction.

Regarding the spacing of the initial ladder rung, it is permissible to vary the distance from the ground, floor, platform, etc., to the first rung up to 12 inches at the bottom of the ladder and then keep a 12 inch spacing for the rest of the length of the ladder.

If I can be of any further assistance, please feel free to contact me.


John K. Barto, Chief
Division of Occupational
Safety Programming