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Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 https://www.osha.gov.

December 6, 1974


Mr. Henry V. Carvill,
Asst. Secretary
Corporate Safety Director
Henry C. Beck Company
4600 First National Bank Bldg.
Dallas, TX 75202

Re: 29 CFR 1926.451(a)(13)

Dear Mr. Carvill:

Regarding your request of November 25, 1974 concerning "Equivalent safe access" to scaffolds, I submit the following comments.

Our National Office in Washington, D. C. has taken the position that if portable ladders are affixed to scaffolds, such ladders must meet the pertinent portable ladder requirements. Ladders built integral to scaffold frames are acceptable if the rungs are of equal length, uniform distances apart, and designed by the scaffold manufacturer as a ladder access for that scaffold. Rungs should be continuously over each other landing levels. Rung spacings up to a nominal 16 1/2" center to center would also be acceptable in providing a safe access. Ledger supports, walk through frames, masonry frames, sidewalk canopy frames, shallow or deep trussed frames and frames with similar designs are not acceptable for use as a ladder access.

The only landing platform requirement for scaffold ladders is in 29 CFR 1926.451(e) and restricted to application on manually propelled mobile scaffolds.

For safe access, landing should be provided at reasonable distances. Such distances can be equated to the maximum of 35' required by 29 CFR 1925.451(e). A ladder safety device that a person could rest against to catch his breath should be an acceptable alternative where a platform is not feasible.

On the subject of your reference to Review Commission decisions, I would like to add the comment that even though some decisions may be adverse to specific standards, this does not negate or revoke the standards in question.

If I may be of further assistance, feel free to contact me.

Sincerely yours,

C. R. HOLDER Associate Assistant
Regional Director for
Technical Support