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First, NOTHING is "OSHA Approved". Does a step cut into earth meet the requirements in Subpart P for safe access? In my opinion, no. The standard requires a stair, ladder, or ramp. Earthen steps can and will crumble from foot traffic, and will not meet that requirement. An earthen RAMP of the correct slope that will permit a worker to walk standing up does meet those requirements (a ramp so steep that you must lean forward to scramble up it does NOT)

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