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.

March 26, 1993

 

 

MEMORANDUM FOR: JAMES W. LAKE, REGIONAL ADMINISTRATOR
REGION X
 
FROM: ROGER A. CLARK, DIRECTOR
[DIRECTORATE OF ENFORCEMENT PROGRAMS]
 
SUBJECT: Standards Applicable to Communication Towers

 


This is in response to your memorandum of January 28, in which you requested applicable standards for ladders, platforms, and climbing devices on and in communication towers.

Our response to Mr. Batt is attached.

Attachment

 

 

 

 



March 26, 1993

Mr. Madison J. Batt, P.E.
Associate TRA Architecture
Engineering Planning Interiors
215 Columbia
Seattle, Washington 98104-1551

Dear Mr. Batt:

Thank you for your inquiry of January 8, addressed to Cliff Glaspey of our Seattle Regional Office, which was forwarded to this office for response. You requested interpretation of the standards at 29 CFR 1910.23, Guarding floor and wall openings and holes, and 29 CFR 1910.27, Fixed ladders, as they pertain to communication towers. We apologize for the delay in this response.

The standards referenced above are both applicable to communication towers for safe access, egress and walking and working surfaces. When it is not feasible to comply with these standards the employer must provide appropriate alternative methods which provide equivalent or greater protection for his employees.

Where there is exposure to falls or to falling equipment and/or tools off the lattice tower platforms where employees stand and perform work, employers are required to protect ladderway floor openings by a standard guardrail system on all sides. A gate equivalent to a guardrail system may be used provided at the access opening, or a guardrail system around the floor opening ladderway may be so offset that a person cannot walk directly into the opening. Single bar gates may not be used in this situation. An open-sided platform where employees stand and perform work and is accessed by a caged fixed ladder on one side of the platform, and where the ladder's cage is at least as high as the guardrail system protecting the work platform, must have the access opening to the ladder protected by a gate equivalent to a guardrail system. A single bar gate may be used only when the platform is used for access to other work locations at different levels. In the event of an OSHA inspection, compliance officers will evaluate the situation in terms of employee exposure, frequency of use, cage diameter, width of opening, height of bar, the type of work usually performed on the platform and any other relevant factors to determine whether a citable hazard exists.

Older towers with improper ladder clearances, no safety devices, or unusable safety devices are not in compliance with current Safety and Health Administration (OSHA) standards. Such towers must be modified to comply with 29 CFR 1910.23, and 29 CFR 1910.27, or provide equivalent or better protection against fall hazards.

Enclosed is proposed 29 CFR 1910, Walking and working surfaces and Personal Protective Equipment (Fall Protection Systems); Notice of Proposed Rulemaking, which will be applicable to communication towers when it is finalized. If sections 1910.22, 1910.23, 1910.24, 1910.25, 1910.27 and 1910.28 of the proposed standard are met, the employer is considered to be in compliance with the OSH Act in regard to the hazards addressed by the proposed standards.

We appreciate your interest in employee safety and health. If we can be of any further assistance, please do not hesitate to contact us.

Sincerely,



Roger A. 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.]