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Standard Interpretations - Table of Contents
• Standard Number: 1910.27; 1910.27(d)(1)(i) ; 1910.27(d)(1)(ii) ; 1910.27(d)(v)

May 27, 2004

Mr. Bryan Gormley
9739 Stoneglen
Colorado Springs, CO 80920

Dear Mr. Gormley:

Thank you for your letter to the Occupational Safety and Health Administration's (OSHA) Region X Office in Seattle, WA, regarding clarification of the OSHA rule at 29 CFR 1910.27 Fixed Ladders. Your letter, which was not dated, was received by our Seattle Office on December 29, 2003, and was sent to the Directorate of Enforcement Programs for a response. 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. We apologize for the delay in our response. Your scenario, questions, and our responses are provided below:

Scenario: My questions are associated with Figure D-9 that depicts a small landing platform with a width of less than four (4) feet from the center of the rungs to the toe board. Figure D-9 requires that in the event that the landing platform is less than four (4) feet, extensions need to be provided that attach to the bottom of the safety cage and extend to the top of the handrail, constraining personnel from falling through the gap between the bottom of the cage and the top of the handrail.

Question 1: The standard was apparently adopted in 1974. If a ladder and associated safety cage were manufactured and installed prior to the inception of the standard, is a retrofit required for that location?

Response: The American National Standards Institute (ANSI) standard ANSI 14.3-1956 was the source standard for §1910.27. The 1910.27 standard which was promulgated in 1971 does not have "grandfather" provisions that would allow the fixed ladders built prior to the publication of the standard to be exempt from 1910.27 requirements. Therefore, ladders and associated safety cages (built and installed prior to the publication of the OSHA 1910.27 standard) which do not meet 1910.27 requirements must be retrofitted to meet 1910.27 requirements, if they are used by the employees of the workplace.

Question 2: What is the maximum horizontal spacing for the extensions? §1910.27(d)(1)(v) "Cages or Wells" states the following: "Cages shall not extend less than 27 nor more than 28 inches from the centerline of the rungs of the ladder. Cage shall not be less than 27 inches in width. The inside shall be clear of projections. Vertical bars shall be located at a maximum spacing of 40 degrees around the circumference of the cage; this will give a maximum spacing of approximately 9½ inches, center to center." Is the intent of Figure D-9 to follow these parameters with a maximum spacing of 9½ inches?

Response: The maximum horizontal spacing between the vertical bars cannot be greater than 9½ inches; this spacing requirement applies to Figure D-9.

Question 3: During the course of an inspection, what emphasis is placed on 29 CFR 1910.27? More specifically, is the standard as shown on Figure D-9 part of the inspection and enforcement procedures?

Response: In the past 10-year period (Jan. 1994 - Jan. 2004), OSHA issued a total of 1,523 citations under the 1910.27 standard. During the course of an inspection, if a compliance officer comes across a fixed ladder (that is used by employees) that does not meet the 1910.27 requirements, including specifications provided in Figure D-9, citations may be issued.

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 Office of General Industry Enforcement at (202) 693-1850.


Richard E. Fairfax, Director
Directorate of Enforcement Programs

Standard Interpretations - Table of Contents

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