• Standard Number:
    1910.27(c)(7)

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 https://www.osha.gov.

November 9, 1999

Mr. Jonathan W. Smith
Hodges & Associations Architects
13642 Omega
Dallas, Texas 75244

Dear Mr. Smith:

Thank you for your September 8, 1999, letter to the Occupational Safety and Health Administration's Dallas Regional Office, requesting a clarification of our Fixed Ladders standard. The letter was forwarded to this office for a response. You are specifically concerned with the application of 29 CFR 1910.27(c)(7), Hatch Covers, to the Bilco Type "S" Roof Scuttle. Because this is a standard-size roof scuttle used throughout industry, you requested a response from the National Office.

Section 1910.27(c)(7), Hatch Covers, states: "The distance from the centerline of rungs or cleats to the edge of the hatch opening on the climbing side shall be not less than 24 inches for offset wells or 30 inches for straight wells. There shall be no protruding potential hazards within 24 inches of the centerline of rungs or cleats; any such hazards within 30 inches of the centerline of the rungs or cleats shall be fitted with a deflector plate."

As currently designed, the Type "S" Roof Scuttle allows for only a 29 inch distance from the centerline of rungs or cleats to the edge of the hatch opening on the climbing side when used with a straight well. A hatch opening with a reduced clearance of 29 inches is acceptable provided the hatch is fitted with a deflection plate at the underside of the hatch opening, as described in the standard.

I hope you find this information helpful. If you have any questions or concerns, please contact the Office of General Industry Compliance Assistance at (202)-693-1850.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs