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.

April 19, 2006

Mr. R. Scott Starling
Jacobs Facilities
501 North Broadway
St. Louis, MO 63102

Dear Mr. Starling:

Thank you for your November 28, 2005, letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You had specific questions regarding regulations related to fixed ladders. Your paraphrased inquiry and our response follow.

Question: Can a fixed ladder with a cage have a continuous length of climb of 62 feet if there is a lateral access platform at the 28-foot level? The platform does not require the climber to exit the ladder to continue the climb.

Response: No. §1910.27(d)(2) requires a landing platform for each 30 feet in height or fraction thereof of a fixed ladder provided with a cage. Under OSHA's proposed revision to Walking and Working Surfaces standard, a 50-foot continuous length of climb for a caged fixed ladder would be allowed (proposed §1910.23(c)(16), 55 Federal Register 13399). Because the lateral access platform you describe would not require the climber to exit the ladder to continue the climb, the ladder in question would have a continuous length of climb of 62 feet, and, therefore, would not be in compliance with either the existing standard or the proposed standard.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions, please feel free to contact the General Industry Enforcement at (202) 693-1850.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs