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.

August 3, 1992

MEMORANDUM FOR:      JOHN B. MILES, JR.
                    REGIONAL ADMINISTRATOR
                    LEO CAREY, DIRECTOR OFFICE OF FIELD
                    PROGRAMS

FROM:                PATRICIA K. CLARK, DIRECTOR
                    DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT:             Specialty Ladders Used in Manholes

This is in response to your March 3 memorandum requesting an interpretation as to whether or not ladders, designed to be used in manhole applications, must comply with the OSHA's construction and general industry side rail width requirements. I apologize for the delay in responding to your inquiry.

In his February 5 letter to you, Mr. Kline of Lynn Ladder and Scaffolding Company stated that a ladder meeting the width requirements of Subpart X will not offer safe access into 24-inch diameter manholes. In order for us to make a determination that compliance with this standard is unsafe, more information is needed. Please provide to us an analysis or clearance comparison of the two different width ladders when used to access 24-inch manholes.

If we can be of any further assistance, please contact Mr. Rolland Stroup in the Office of General Industry Compliance Assistance on (202) 523-8031 or Mr. Dale Cavanaugh in the Office of Construction and Maritime Compliance Assistance on (202) 523- 8124.