The following letter can be found on OSHA's website HERE.
|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.
July 12, 2000
Mr. Hal Swindell
4210 Church Road
Mount Laurel, New Jersey 08054
Dear Mr. Swindell:
Thank you for your November 12, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) [Directorate of Enforcement Programs (DEP)]. You have questions regarding Roof Access Hatches and Fixed Ladders. We apologize for the delay in our response.
Question 1: Is it necessary for a roof access hatch equipped with a fixed ladder and a hatch cover to have a device to grab onto to exit and enter the hatchway?
Question 2: If so, does the grab device in question #1 above have to extend 36 inches or greater above the roof line?
Reply: No. OSHA's general industry standard for fixed ladders is found in 29 CFR 1910.27. Section 1910.27(c)(7) and Figure D-6 (attached) specify the relationship for a fixed ladder to an acceptable hatch cover, but there is no specific requirement for grab bars. Also, the American National Standards Institute (ANSI) standard A14.3-1992, Safety Requirements for Fixed Ladders, section 184.108.40.206, Extensions for Individual Rung Ladders, stipulates that the general requirement for extension of the ladder above the access/egress level does not apply to ladders "intended for manholes and terminations with hatches." However, please be aware that while 1910.27 does not call for grab bars in this situation, the use of guardrails around the opening itself may be necessary (see the following question and answer).
Question 3: Is it necessary to protect the opening if the cover is left up while personnel are on the roof?
Answer: Yes. In most situations 29 CFR 1910.23 requires that the exposed sides of openings in floors have some form of guardrail protection. When the hinged cover for an opening is left up, there are sides exposed which must be appropriately protected.
Please note that in view of a decision of the Occupational Safety and Health Review Commission, 1910.23 might not be applicable to openings in roofs. However, we believe that there are recognized hazards associated with openings in roofs. For example, ANSI standard A1264.1- 1995, Safety Requirements for Workplace Floor and Wall Openings, Stairs, and Railing Systems, requires guardrail protection for the exposed sides of ladderway openings in any working/walking surface. Unprotected openings in roofs could, therefore, be cited under the general duty clause of the Occupational Safety and Health Act, which requires an employer to provide a workplace free from recognized hazards.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may wish to consult OSHA's website. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement] at (202) 693-1850.
Richard E. Fairfax, Director
[Directorate of Enforcement Programs]
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