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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

December 15, 1977

Mr. James Somero
Vanguard Manufacturing Inc.
Temple Road
New Ipswich, New Hampshire 03071

Dear Mr. Somero:

This is in response to your letter of October 26, 1977, regarding an interpretation of the standards regulating access for tubular steel scaffolding.

In 29 CFR 1926.451(a)(13) the standard states: "An access ladder or equivalent safe access shall be provided." The "equivalent safe access" to any scaffolding may include permanent or temporary stairways, suitable ramps or runways, or configurations that are similar to ladders as described in 29 CFR 1926.450 ladders; the main requisite being that reasonable safety of employees is assured when using such means of access and egress.

If would appear from your enclosed drawing that your ladder attached to the scaffold frame is not in compliance with 29 CFR 1926.451(a)(13). However, consideration of this variable rung spacing type of access is being reviewed at this time by the Office of Standards Development.

Thank you for your concern and continued interest in occupational safety and health.


John K. Barto, Chief
Division of Occupational
Safety Programming