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 http://www.osha.gov.
May 18, 1992
Mr. Scott Gallagher President
24626 131 Place S.E.
Kent, Washington 98031
Dear Mr. Gallagher:
This is in response to your March 13 letter requesting a statement of compliance from the Occupational Safety and Health Administration (OSHA) for the Gallagher Step Extension. I apologize for the delay in responding to your inquiry.
OSHA does not approve nor endorse products. The variable working conditions at jobsites and possible alterations, misuse, or misapplication of an otherwise safe product could easily create a hazardous condition beyond the control of the manufacturer. However, we have reviewed the product drawing enclosed with your letter and it appears that if the step extension is used correctly, it would comply with OSHA's proposed rules for hook-on ladders used for accessing scaffold type platforms as shown in the pictures you sent to OSHA. However, please note, there are no existing rules that specifically address your step extension.
As you are aware, OSHA considers its standards as minimum requirements and, relies on individuals to provide protection that is not otherwise specifically required by the regulations. We commend you and your associate for making that extra effort to further reduce the likelihood of injury when installing drywall.
If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 523-8136.
Roy F. Gurnham, P.E., Esq. Director
Office of Construction and Maritime