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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

February 25, 1983

W.D. Braswell, C.S.P.
Vice President, Safety
A.A. Beiro Construction Company, Inc.
3015 Colvin Street
Alexandria, Virginia 22314

Dear Mr. Braswell:

This is in response to your letter of February 8, 1983, requesting a clarification of 29 CFR 1926.451(a)(13). The response to your five points is as follows:

1. It is not practical or intended that employers provide ladder access at all times for employees assembling or dismantling scaffold components; however, other safe access must be provided.

2. End frames are acceptable for access if the rungs are designed by the scaffold manufacturer as an access ladder, and they are arranged in such a way that they form a continuous series of steps from the scaffold top to its bottom. Maximum spacing between rungs shall not exceed 16 1/2 inches.

3. Portable wood or metal ladders used to provide safe access must comply with 29 CFR 1926.450(a)(3) and (4).

4. The fixed ladder standards do not apply to scaffolds.

5. The ladder standards do not apply to scaffold structures when they are built into the scaffold components.

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


John K. Barto Chief,
Division of Occupational Safety Programming