|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.
March 7, 1997
Mr. Don Jackson
The Journal of Light Construction
RR #2 Box 146
Richmond, Vermont 05477
Dear Mr. Jackson:
This is in response to your telefax of January 22, concerning ridge hook-supported ladders.
First, I would like to respond to your specific questions. Employers can use ridge hook-supported ladders to access staging provided the requirements for access in Subpart L are met.
In addition, employers can use ridge hook-supported ladders for routine repairs if they meet the requirements of Subpart X or Subpart L as appropriate.
Responding to Mr. Bushway's questions, I submit the following:
All ladder use must comply with Subpart X unless used for scaffold access, then Subpart L offers additional options. In addition, with regard to ladders, fall protection is more than ladder climbing devices and cages. It also includes angle of placement, securing, clearance, extension above the landing, support, three point contact while climbing, and many other considerations that are intended to prevent falls.
Chimney cleaning and flashing repair are covered by OSHA regulations. A ridge hook-supported ladder may be used to do these activities, and no personal fall arrest system is required when working from the ladder. However, if the employee gets off the ladder, then Subpart M
and OSHA [STD 03-00-001 (formerly STD 3.1)] apply [applies].
[This document was edited on 12/5/12 to strike information that no longer reflects current OSHA policy.]
[If you need any additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax (202) 693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.]
Roy F. Gurnham, Manager
[Directorate of Construction,
Office of Construction Standards and Guidance]