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, 1981

Mr. R. E. McConomy
Engineering Services
Westeel Rosco Limited
1 Atlanta Avenue
Toronto, Ontario
M6K1X7

Dear Mr. McConomy:

This is in response to your letter of November 13, 1981, requesting a clarification of a fixed ladder requirement in 29 CFR 1910.27.

The Occupational Safety and Health Administration would allow the connection of the vertical bars to the horizontal hoop using a bolt and nut with the head of the nut placed on the inside of the cage. However, the connection must develop enough strength to meet the load requirement in 29 CFR 1910.27(a)(1).

If we may be of further assistance, please call or write.

Sincerely,



Patrick R. Tyson
Acting Director,
Federal Compliance and State Programs