OSHA INSTRUCTION STD 1-15.4 OCTOBER 30, 1978

OSHA PROGRAM DIRECTIVE #100-46

TO: REGIONAL ADMINISTRATORS - OSHA

Subject: Interpretation of 29 CFR 1910.268(h)(8) Ladders Requirements Applying to Metal Manhole Ladders

1. Purpose

To provide specific interpretation as to the intent of the application of 29 CFR 1910.268(h)(8)(i), (ii), (iii), (iv), (v), and (vi).

2. Directive Affected

None.

3. Background

a. The intent of the proposed and final standard at 29 CFR 1910.268(h)(8), Metal Manhole Ladders, published in the Federal Register on August 28, 1973, and March 26, 1975, respectively, was to limit its scope to "portable metal manhole ladders.

b. This intent is evident when Section 1910.268 (h)(8) is compared to 29 CFR 1910.26 - the General Industry standard which applies to portable metal ladders. The language of section 1910.26 is virtually identical to that contained in Section 1910.268(h)(8). Moreover, the language of Section 1910.268(h)(8) is inconsistent with 29 CFR 1910.27 - the General Industry standard which applies to fixed ladders.

4. Action

The enforcement of 29 CFR 1910.268(h)(8)(i) through (vi) as written shall be limited to "portable" metal manhole ladders used in the telecommunication industry. Fixed manhole ladders are not covered by 29 CFR 1910.268(h)(8).

OSHA INSTRUCTION STD 1.15.4 OCTOBER 30, 1978

5. Effective-Date

This directive is effective immediately and shall remain in effect until canceled or superseded.

Barry J. White Associate Assistant Secretary for Regional Programs

Distribution: A-1 B-2 C-1 D-4 & 5 Training Center