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.

May 12, 1975

Mr. Ingo Zeise
Construction Division
Engineering Department
E.I. du Pont de Nemours & Company
1007 Market Street
Wilmington, Delaware 19898

Dear Mr. Zeise:

This is in response to your letter of April 3, 1975 regarding the intent of general requirements of ladders, [29 CFR 1926.451(e)(2) and 1926.1053(b)(1)] of the Construction Safety and Health Regulations. In addition, this confirms Jeff Campbell's conversation with you on April 24, 1975.

We feel the intent of 1926.451(e)(2) and 1926.1053(b)(1), as written, addresses the subject adequately. Further points of clarification are: Ladder side rails with rungs removed above the landing are not required on manufactured portable wood or metal ladders; step through side rails (ladder extensions) are required on fixed or job-made ladders where specified on OSHA standards; and, there may be special conditions here grab rails would be required due to hazardous walking surfaces such as slippery conditions at the point of access to the ladder at the landing.

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


Donald A. Shay, Director
Office of Compliance Programming

[Corrected 5/28/2004]