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