Elevator Penthouse - Movable Ladder to clean gutter?

[redbird11]

Hello,
I have an elevator penthouse on top of a 5 story building. The gutter is 11' above the adjacent flat roof surface. The penthouse roof has nothing else requiring maintenance. Is it allowable to maintain this gutter with a movable ladder or would a permanent ladder need to be installed?

2018 IBC and IMC. Referencing 2018 IMC

"306.5 Equipment and appliances on roofs or elevated structures:
Where equipment requiring access or appliances are located on an elevated structure or the roof of a building such that personnel will have to climb higher than 16 feet (4877 mm) above grade to access such equipment or appliances, an interior or exterior means of access shall be provided. Such access shall not require climbing over obstructions greater than 30 inches (762 mm) in height or walking on roofs having a slope greater than four units vertical in 12 units horizontal (33-percent slope). Such access shall not require the use of portable ladders. Where access involves climbing over parapet walls, the height shall be measured to the top of the parapet wall."

 

[RLGA]

I wouldn't consider a gutter a piece of equipment or an appliance.

 

[TheCommish]

Is there anything that is on the roof that has a motor, engine, filter, flame, valve? If not then in my opinion there is no equipment to maintain

 

[e hilton]

How much roof is there around the penthouse? How high is the perimeter parapet?

 

[redbird11]

Is there anything that is on the roof that has a motor, engine, filter, flame, valve? If not then in my opinion there is no equipment to maintain

Nope, just a white roof membrane sloping to
the gutter.

 

[redbird11]

How much roof is there around the penthouse? How high is the perimeter parapet?

Over 20’ around it and when you do reach the edge of the main roof there are guardrails.