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, 1991

Mr. Edward A. Donoghue
Edward A. Donoghue Associates Inc.
Code and Safety Consultant to NEII
Shushan Road
Post Office Box 201
Salem, New York 12865-0201

Dear Mr. Donoghue:

Thank you for your letter of October 7, addressed to Gerard F. Scannell, Assistant Secretary of Labor, requesting an interpretation regarding Occupational Safety and Health Administration (OSHA) requirements for clearances behind permanently installed vertical ladders in elevator pits.

The relevant OSHA standard (29 CFR 1910.27(c)(4)) requires a distance of 7 inches (17.78 cm) from the centerline of rungs, cleats, or steps to the nearest permanent object in back of the ladder. When unavoidable obstructions are encountered, the minimum clearance requirement of 4.5 inches (11.43 cm) is acceptable, as shown in figure D-3 of 29 CFR 1910.27.

The standard at 29 CFR 1910.27(c)(5) requires a minimum clearance of 4 inches (10.16 cm) from the centerline of grab bars to the nearest permanent object in back of the grab bars. This clearance requirement is the distance from the grab bars, not the rungs, cleats, or steps; therefore, it does not pertain to toe clearances.

American National Standard Institute (ANSI) A14.3, for Ladders - Fixed-Safety Requirements, is the source standard for 29 CFR 1910.27. The toe clearances of 4.5 and 7 inches (11.43 and 17.78 cm) were derived, from ANSI A14.3 - 1956, Section 5.4. To accommodate existing ladder, installations at unavoidable, obstructions (including structural beams, foundation walls, air ducts, water pipes, etc.), the 4.5 inches (11.43 cm) toe clearance was included in the April 10, 1990, Notice of Proposed Rulemaking for Subpart D, Walking and Working Surfaces and Personal Protective Equipment. The aforementioned clearances are applicable to existing ladder installations in workplaces, including elevator pits.

Thank you for your interest in occupational safety and health. If we may be of further assistance, please contact us.


Patricia K. Clark, Director
[Directorate of Enforcement Programs]

[Corrected 4/4/2005.

Note: On April 10, 1990 OSHA published proposed revisions to Walking and Working Surfaces; Personal Protective Equipment (Fall Protection Systems); Notices of Proposed Rulemaking; Slips; Falls;Trips in
Federal Register 55:13360-13441. It is available electronically only as an abstract. On May 2, 2003 OSHA reopened the rulemaking record on the proposed revisions to Walking and Working Surfaces and Personal Protective Equipment (Fall Protection Systems). It was re-published in its entirety in Federal Register 68:23527-23568 and is available electronically.]