• 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 https://www.osha.gov.

December 2, 1981

Mr. Dale E. Ordoyne
Marketing Manager Lapeyre Stair, Inc.
P.O. Box 50699
New Orleans, Louisiana 70150

Dear Mr. Ordoyne:

This is in further response to your letter of October 12, 1981, requesting a clarification of the Occupational Safety and Health Administration's (OSHA) position concerning the use of your alternating tread type stair, the Lapeyre Stair.

OSHA's General Industry Standards do not, at the present time, clearly address alternating tread type stairs similar to yours. All too often the rapid pace of technological innovation exceeds our rulemaking capacity. It is our intent, however, to advance our time schedule for dealing with this particular issue.

However, based on a thorough review of your stair, it is our position that the stair is safe for use, meets the intent of the Occupational Safety and Health Act and no citations will be issued if it is properly installed and maintained per your specifications. A directive incorporating this determination will be provided to OSHA's field compliance officers in the near future.

Thank you for your patience in this matter. If I may be of further assistance, please let me know.


Mark D. Cowan
Deputy Assistant Secretary