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.

December 2, 1980

Mr. James Mohart
Black & Veatch
P.O. Box No. 8405
Kansas City, Missouri 64114

Dear Mr. Mohart:

This is in response to your recent letter requesting clarification of our requirements for manhole steps in walls of risers or conical top sections of manholes. This also confirms a telephone conversation with a member of my staff, Mr. Simms.

As indicated in our program directive, 29 CFR 1910.27 does not apply to individual steps in walls of risers or conical top sections of manholes. OSHA Instruction STD 1-1.9 provides the applicable requirements in this matter, and direct alignment of individual rung or steps in manholes was assumed.

The Directorate of Safety Standards Programs has not been petitioned to develop standards permitting individual steps in manholes to be installed with a staggered alignment.

If we may be of any further assistance, please feel free to call or write.

Sincerely,



John K. Barto
Chief, Division of
Occupational Safety Programming