Standard Interpretations - Table of Contents
• Standard Number: 1910.27; 1910.27(d)(1)(i); 1910.27(d)(1)(ii); 1910.27(d)(5)


November 8, 2007

Mr. John T. Dooley, LLC.
The Dooley Building
5434 King Avenue @ Route 38 East
Suite 202
Pennsauken, NJ 08109-1197

Dear Mr. Dooley:

Thank you for your September 26, 2006 letter regarding the Occupational Safety and Health Administration's (OSHA) enforcement policy on fixed ladders that are used at workplaces. In your letter you referenced OSHA's letter of interpretation dated May 27, 2004 regarding the required retrofit of existing fixed ladders when the landing platform, as depicted in Figure D-9 of 29 CFR 1910.27, is less than 4 feet. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. We apologize for the delay in our response. Your paraphrased questions and our response are provided below.

Question 1: What is the enforcement policy regarding OSHA standards 1910.27(d)(1)(i) and 1910.27(d)(1)(ii) that reference Figures D-7, D-8, and D-9 contained in 1910.27?

Response 1: OSHA standard at 29 CFR 1910.27(d)(1)(i) provides:
Cages or wells (except on chimney ladders) shall be built, as shown on the applicable diagrams, covered in detail in figures D-7, D-8, and D-9, or of equivalent construction.
29 CFR 1910.27(d)(1)(ii) states:
Cages or well (except as provided in subparagraph (5) of this paragraph) conforming to the dimensions shown in figures D-7, D-8, and D-9 shall be provided on ladders of more than 20 feet to a maximum unbroken length