For years, OSHA had taken a position on when/where “swing gates” were actually required and that position was that it did NOT apply to fixed ladders on the edge of a platform. Then in 2009 they officially stated their enforcement position in a Regional Memo that DID include ladderway opening on the edge of a platform. This 2009 memo is actually helpful in understanding their position and reasoning for their enforcement position. In it, OSHA states…