June 30, 2014

Mr. Mark Hochstetler
President
Honeyville Metal, Inc.
4200 South 900 West
Topeka, IN 46571-9142

Dear Mr. Hochstetler:

Thank you for your letter dated September 16, 2013, to the Occupational Safety and Health Administration (OSHA) for a clarification of OSHA's standards pertaining to 29 CFR 1910.27, Fixed ladders. This constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.

Your paraphrased question and our response follow.

Background/Scenario: Honeyville Metal, Inc. fabricates grain handling equipment comprised of bucket elevators, drag conveyors, and screw conveyors along with conveyor supports and towers. We also fabricate dust collection equipment comprised of fans, cyclones, filter baghouses, and suction/blow pipe and fittings. The service ladders that we fabricate are constructed of hot rolled carbon steel flat bars for the side rails and 7/8 inch diameter solid steel round bars for the rungs. The ladder is a welded assembly and it is hot dip galvanized as the final surface treatment. We believe our service ladder, safety cage assembly, and the mounting on our equipment is all in OSHA compliance except for the smooth ladder rung. Our intention is to replace the current rung (7/8 inch diameter solid steel round bars) with a 14 gauge hot rolled carbon steel, die formed rung that includes raised protrusions to provide a grip surface for the person's feet while climbing the service ladder.

The technical specifications for the newly designed ladder rungs are as follows:

• 14 gauge hot rolled carbon steel, die formed round rung with 12 inches of distance between rungs and are uniform throughout the ladder length 1.25 inch diameter (1.1875 inch diameter minimum) x 16 inch long
• Raised grip protrusions are .375 inch at the base, .1875 inch at the top, and it is raised .080 inches
• Raised grip protrusions are on a .750 x .750 inch stagger pattern over a 15 inch long span
• Raised grip protrusions are located at 10:30 and 1:30 when viewed from the end
• And .250 and .3125 inch open gap at the bottom to allow the hot dip galvanizing to flow throughout

Question: Would the changes that we have made to our fixed ladders be in compliance with 29 CFR 1910.27, Fixed ladders?

Response: Firstly, please note that OSHA does not certify the safety of products. Nor does it endorse or approve products.

OSHA standard 1910.27(b)(1)(i) requires all metal ladder rungs to have a minimum diameter of three-fourths inch and the ladder rung diameter that you state in your scenario is for a minimum of 1.1875 diameter, which complies with the OSHA standard.

OSHA standard 1910.27(b)(1)(ii) requires the distance between rungs, cleats, and steps of fixed ladders not to exceed 12 inches and to be uniform throughout the length of the ladder and the distance between the rungs that you state in your scenario is for a distance between ladder rungs of 12 inches, which complies with the OSHA standard.

OSHA standard 1910.27(b)(1)(iii) requires that the minimum clear length of rungs or cleats shall be 16 inches and you state in your scenario that the clear length of rungs is 16 inches, which complies with the OSHA standard.

Additionally, the Agency does not have enough information to determine whether the raised grip protrusions added to the rungs meet the requirements under 29 CFR 1910.27 because they may be considered a projection, which is not allowed under OSHA standard 29 CFR 1910.27(b)(1)(iv). Nor can OSHA determine whether the surface finish presents a fall hazard to an employee while climbing the fixed ladder because environmental conditions may cause an employee to slip while climbing the ladders. Please consider that the Agency cannot make a determination of work or environmental conditions in a workplace that OSHA has not evaluated or inspected for workplace hazards.

Finally, the following OSHA requirements for the surface finish and projections on fixed ladder rungs are listed below:

1910.27(b)(1)(iv) Rungs, cleats, and steps shall be free of splinters, sharp edges, burrs, or projections which may be a hazard.

910.27(b)(1)(v) The rungs of an individual-rung ladder shall be so designed that the foot cannot slide off the end. A suggested design is shown in figure D-1.

FIGURE D-1. - Suggested design for rungs on individual-rung ladders.

1910.27(b)(7)

"Protection from deterioration."

1910.27(b)(7)(i)

Metal ladders and appurtenances shall be painted or otherwise treated to resist corrosion and rusting when location demands. Ladders formed by individual metal rungs imbedded in concrete, which serve as access to pits and to other areas under floors, are frequently located in an atmosphere that causes corrosion and rusting. To increase rung life in such atmosphere, individual metal rungs shall have a minimum diameter of 1 inch or shall be painted or otherwise treated to resist corrosion and rusting.

If you, as the manufacturer, feel that the surface finish might present a fall hazard to an employee, we encourage you to consider alternate surface treatments, such as a non-skid coating or other anti-slip treatments that prevents a slip hazard to employees while climbing the ladder.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a Standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have further questions, please feel free to contact the Office of General Industry and Agricultural Enforcement at (202) 693-1850.

Sincerely,

Thomas Galassi, Director
Directorate of Enforcement Programs

i"Rungs and cleats."
1910.27(b)(1)(i)
All rungs shall have a minimum diameter of three-fourths inch for metal ladders, except as covered in paragraph (b)(7)(i) of this section and a minimum diameter of 1 1/8 inches for wood ladders.
1910.27(b)(1)(ii)
The distance between rungs, cleats, and steps shall not exceed 12 inches and shall be uniform throughout the length of the ladder.
1910.27(b)(1)(iii)
The minimum clear length of rungs or cleats shall be 16 inches.