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.

April 7, 1975

Mr. Monte Geiger
Associated General Contractors
Inland Empire Chapter E.
4935 Trent
Spokane, WA 99220

Dear Monte:

This is in answer to your request for an interpretation on OSHA standard [1926.451(e)(2) and 1926.1053(b)(1)] concerning ladders.

We are in agreement with the interpretation you referenced; that is, ladders extending more than 36 inches above the landing need not have the rungs above the landing removed so as to facilitate employees stepping between the side rails. Common sense may dictate that this be done in certain instances, but the standards do not require it.

Thank you for your interest and if I can be of any further assistance, please let me know.


John A. Granchi
Associate Assistant Regional Director
Office of Technical Support

[Corrected 5/28/2004]