October 9, 1984

Richard W. McClung, P.E.
Project Manager
Galson & Galson Consulting Engineering
6601 Kinkville Road E.
Syracuse, New York 13057

Dear Mr. McClung:

This is in response to your letter of October 1, 1984, in which you requested a written confirmation of an interpretation of the Occupational Safety and Health Administration's (OSHA) standard 29 CFR 1910.27(d)(2), given to you by the Syracuse Area Office in consultation with this Regional Office.

We would like to clarify the following:

The standard 1910.27(d)(2) requires landing platforms on fixed ladders when they are used to ascend to heights exceeding 20 feet. These landing platforms are required for every 30 feet of height or fraction thereof, except that, where no cage, well, or ladder safety device is provided, landing platforms are required for every 20 feet of height or fraction thereof. If an employer used a fixed ladder in a manhole, it would be the same as a well, so 30 ft. would be correct. However, ANSI A14.3-1984 changed this to 50 ft., so up to 50 ft. in a manhole would be "de minimus". Individual rung ladders in manholes are covered by this standard. Manhole steps are not covered by this standard.

Ladder safety devices are not required by the OSHA standard 1910.27. If they are provided, they may be used anytime.

When the use of a cage, well, or landing platform on fixed ladders is not feasible or it may be more hazardous in emergency situations, proper ladder safety devices are acceptable to protect employees from the hazard of falling. If a safety harness attached to a cable is used by all who enter a manhole, and the cable is part of a fall arrest system, there is no need for a ladder safety device.

The entry into a storm sewer manhole can be dangerous. Because of this, the employer shall take the necessary actions to protect the employee or employees who enter the confined space. The employer shall establish and implement a confined space- entry procedure which should include, among other things: the identification and evaluation of hazards or potential hazards encountered in the confined space, testing for oxygen level, flammable gases, vapors, solids or airborne toxic materials, training of employees and attendants, and provisions for proper personal protective equipment, etc.

In your letter, you wrote that the most common hazard in descending into the sewer system is to be overcome by sewer gases that are common in this type of system. This kind of accident can be prevented if the employer provides adequate ventilation in the sewer system and/or the employees are provided with self-contained breathing apparatus type respirators, as required by OSHA, and properly trained in their use.

We hope this information is useful to you. If we may be of further assistance, please contact us.

Sincerely,



Cathie M. Mannion
Assistant Regional Administrator
for Technical Support




October 1, 1984

Mr. Gerald P. Reidy
Regional Administrator
US DOL-OSHA
1515 Broadway Avenue
New York, New York 10036

ATTN: ARA Technical Support Mr. Sanchez/Mr. Switzer

RE: Storm Sewer Manholes Ladder Safety Regulations

Dear Mr. Reidy:

OSHA regulation 1910.27(d)(2) and ANSI A14.3-1956 Safety Code for Fixed Ladders call for rest platforms whenever ladders are in excess of 20 feet. We are currently working on a storm sewer project which includes ten manholes which exceed 20 feet in depth. These manholes vary in depth from 20' - 5" to 28' - 10" with the majority being in the 24' - 25' range.

If these regulations apply to the manholes, a rest platform would be required at the mid-point of each manhole. We believe that this platform would be a dangerous hazard rather than a safety device in this particular application. When a man descends into a storm manhole, he is required to wear a safety harness attached to a cable, and to have a second person standing at the top of the manhole. The most common hazard in descending into the sewer system is to be overcome by sewer gases that are common in this type of system. When this occurs, the man at the surface must pull the worker out of the manhole. A rest platform would be detrimental to this process, and could actually prevent the worker from escaping the manhole. Therefore, we are quite concerned about the danger posed by the installation of a landing platform.

This matter was discussed with Tom Rezsnyak at the Syracuse Office at the Department of Labor - OSHA, and he checked with your office for an interpretation. It is my understanding that this interpretation agreed that a landing platform was not applicable to this application, but that a ladder safety device, as described in ANSI standard A14.3-1974, Article 6 would be required. Our design is proceeding on the basis of a ladder safety device, but we would appreciate confirmation of your interpretation to this effect in writing as soon as possible.

We appreciate your cooperation and assistance in resolving this matter. If you have any questions, or require any other information from me, please do not hesitate to give me a call. I will be waiting for your reply.

Yours very truly,

GALSON & GALSON



Richard W. McClung, P.E.
Project Manager