Question: Are fixed stairs attached to the exterior of tanks required to comply with the requirements of §1910.25(b) or would those stairs fall under the exemptions in §1910.25(a)?

Answer:

The exception from the stair requirements in §1910.25(a) only applies to stairs serving floating roof tanks, stairs on scaffolds, stairs on self-propelled motorized equipment, or stairs designed into machines or equipment. For stairs on the exterior of other tanks, employers would have to ensure they comply with the requirements in §1910.25(b) and (c).