OSHA Stairs Built into Equipment Definition 1

[Bagman2524]

OSHA 1910.25 states:

Application. This section covers all stairways (including standard, spiral, ship, and alternating tread-type stairs), except for stairs serving floating roof tanks, stairs on scaffolds, stairs designed into machines or equipment, and stairs on self-propelled motorized equipment.”

However, there is no definition as to what stairs designed into machines or equipment is. How do you differentiate from stairways used to access equipment and stairs designed into equipment?

Definition of Stairway and Standard stairs provided for reference below.

In section 1910.21 (Definitions):
>
> Stairway (stairs) means risers and treads that connect one level with another, and includes any landings and platforms in between those levels. Stairways include standard, spiral, alternating tread type, and ship stairs.
>
> Standard stairs means a fixed or permanently installed stairway. Ship, spiral, and alternately tread-type stairs are not considered standard stairs

All I know is P/A and Mc/I

 

[JStephen]

Hard to say without knowing the specifics involved. It's sort of like that definition of pornography, can't define it, but know it when I see it.
One indication is whether it's furnished by the equipment manufacturer and made into or on the equipment, or whether it's furnished by the building contractor with the building.

 

[BridgeSmith]

Presumably, it's referring to stairs that integrally part of the framework or structure of the equipment assembly or housing. Probably doesn't include stairs that are bolted onto the equipment in discrete locations, that have their own support structure.

Edit: I like JStephen's criteria better than mine - "...furnished by the equipment manufacturer..." would seem to be the better way to make the distinction.

 

[WARose]

Is kind of confusing isn't it? For me, the cutoff would be: are the stairs attached to (equipment) vendor supplied framing? (Like a skid.) And supplied by that vendor?

 

[JStephen]

"Equipment Stairs" here:

"Building Stairs" here:

I believe these would actually count as "Equipment Stairs":

https://commons.wikimedia.org/wiki/...t,_Boston_(Suffolk_County,_Massachusetts).jpg

These could go either way, but I'm inclined towards the "Equipment" category: