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Standard Interpretations - Table of Contents
• Standard Number: 1910.21; 1910.21(e)(1) ; 1910.268; 1910.268(h)(2)

This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence.

July 23, 2007

Mr. Gary Paustian
318 S. Westwood Blvd.
Nampa, ID 83686

Dear Mr. Paustian:

Thank you for your January 3, 2007, letter to the Occupational Safety and Health Administration (OSHA). Your letter has been forwarded to OSHA's Directorate of Enforcement Programs. You had questions regarding OSHA's Telecommunications standard, 29 CFR §1910.268 and the requirements for ladders, 29 CFR 1910.268(h). Your scenario, paraphrased questions and our responses follow.

Scenario: Technicians are required to maintain radio antennas and transmission lines on a variety of communications towers. Some towers do not have a separate ladder installed, causing technicians to climb the towers using the cross-member supports, effectively making them a ladder.

Question 1: Do the requirements for fixed ladders found in 29 CFR 1910.268(h)(2), particularly the requirements for width and diameter of rungs and steps, apply to structural cross-members that are used for climbing?

Response: No, the requirements of 29 CFR 1910.268(h)(2) do not apply to cross-member supports, because the cross-member supports you describe are not ladders. The term ladder, as used in §1910.268, is defined at §1910.21(e)(1), which states "(a) ladder is an appliance usually consisting of two side rails joined at regular intervals by cross-pieces called steps, rungs, or cleats, on which a person may step in ascending or descending." Cross-members do not have side rails and cross-pieces that could be considered steps, rungs, or cleats, and therefore, cannot be considered ladders. While OSHA's telecommunications standard does not address climbing structural components such as the lattice-work (or cross-members), please note that this response does not constitute an endorsement of the safety of this practice.

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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