Standard Interpretations - Table of Contents
• Standard Number: 1910.23; 1910.23(a)(2); 1910.27

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.


September 29, 2009

MEMORANDUM FOR: REGIONAL ADMINISTRATORS

FROM: RICHARD E. FAIRFAX, DIRECTOR
DIRECTORATE OF ENFORCEMENT PROGRAMS

SUBJECT: Guarding of Access Openings to Fixed Ladders

The purpose of this memorandum is to clarify the requirements for guarding access openings to fixed ladders. Differences in the regulatory text between paragraphs 1910.23(a)(2) and 1910.23(c)(1) and silence on this issue in paragraph 1910.23(c)(2) and in the fixed ladder standard at 1910.27 have led to some confusion.

Openings on platforms are regulated by different paragraphs of §1910.23. Paragraph §1910.23(a) covers floor openings, including access openings at the edge of a platform. Paragraph §1910.23(b) covers wall openings and wall holes. Paragraph §1910.23(c) covers the edges of open-sided floors and platforms, but not the access openings at the edge of the platform or through the floor.

The governing requirement for the guarding of ladderway floor openings and platforms is paragraph 1910.23(a)(2)