- 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 http://www.osha.gov.
February 26, 1996
Mr. Gordon Lyman
LeBlanc Communications, Inc.
R.R #1, Box 647
Dickinson, Texas 77539
Dear Mr. Lyman:
This is in response to your letter of February 22, a previous letter you sent to Mr. Gerald Reidy, and confirms a telephone conversation with a member of my staff. Your letter requested a clarification of Occupational Safety and Health Administration (OSHA) standards, Section 1910.268 Telecommunications.
Regarding 29 CFR 1910.268 Telecommunications, and more specifically 1910.268(h)(2), the standard requires that all fixed ladder rungs have a minimum clear width of 12 inches. The application that you specify in your letter would clearly be covered by the requirements of this section. Other width and length requirements relating to ladders found elsewhere in OSHA standards (i.e. 29 CFR 1910.27 or 1910.268(h)(8)) do not apply to fixed ladders on telecommunications towers. Those standards apply only for general walking, working surfaces and metal manhole ladders, respectively.
We hope this clarification has provided you with the assistance you sought. If we can be of further assistance, please contact Margo Daniel of my staff at (202)219-8041, #107.
Raymond Donnelly, Director
Office of Safety Compliance Assistance
February 22, 1996
U.S. Department of Labor (OSHA)
200 Constitution Ave., Room N 3107
Washington, DC 20210
Attn: Margo Daniels Ref: Fixed Ladder Standard for Communication Towers
Dear Ms. Daniels
As we have all learned the last few months in our dealings with SENRAC, communication towers is a special industry that does not fall under any particular subpart.
LeBlanc Communications Inc. is a company that manufactures and installs all types of communication towers. The manufacturing is accomplished using OSHA 1910.268 as our guideline for manufacturing. This is the only area that actually uses the word tower. In this standard the width is 14 inches, the other standard states 16 inches. Our company, as well as many other manufacturers have built thousands of towers using the above referenced specifications. LeBlanc is currently having a conflict with a customer that states we are using the wrong standard for the ladder on the tower. In this particular case, the ladder has a rigid safety climb attached to the center of the ladder.
LeBlanc uses one hundred percent fall protection while building the structure, so the ladder becomes a mute point during the erection.
For your reference I have enclosed the drawings pertaining to the ladder and a letter I had written to the project manager explaining our understanding. LeBlanc would appreciate an interpretation from your office to determine if we are indeed following the correct standard.
Should you have any questions, please contact me at 713-339-1582. I look forward to hearing from you.
December 1, 1995
LeBlanc Communications Inc.
2301 Bridgeport Drive
Sioux City, Iowa 51111
Attn: Steve Fry Ref: OSHA Ladder Requirements
I received a fax from Cory Springer this morning referencing the disagreement on ladder specifications. I have reviewed three specifications (1910.268, 1910.27 and ANSI A14.3) and there is an obvious difference between 1910.268 and the other two.
LeBlanc must follow 1910.268 due to the following:
a. We fall under Subpart R - Special Industries - telecommunications. Any topic referenced in this Subpart takes priority over any other Subpart.
b. 1910.268(h)(2) specifically uses the word tower. The word tower is not used in the other two documents.
I have enclosed the documents for your perusal. If you need anything else, please call.