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.

July 20, 1992

Mr. John Wilson
Safety Administrator
American International Construction, Inc.
14603 Chrisman
Houston, Texas 77039

Dear Mr. Wilson:

This is in response to your company's letter of February 5 requesting an interpretation of Occupational Safety and Health Administration standards addressing the use of ladders and fall protection by steel erectors. I apologize for the delay of this response.

In regard to whether the requirement for stairways or ladders at all points of access where there is a break in elevation of 19 inches or more (29 CFR 1926.1051(a)) applies to steel erectors, please be advised that all of Subpart X-Stairways and Ladders applies to steel erectors as well as to all other trades at construction sites. However, although the definitions and provisions of Subpart X require all points of access to be provided with a ladder or stairway, the standard is not intended to require such facilities at every location where employees change elevations. The standard is intended to require a ladder or stairway between levels in at least one location between levels so that employees can change levels in an easy, safe, and convenient manner. The obvious reason is to allow access to different elevations in a way that minimizes the potential for fall injuries that can result when employees are otherwise required to climb on items (i.e. columns, cross-bracing on scaffolds) not properly designed for climbing. In situations where non-routine access is required, such as climbing vertical steel to make initial connections, and where fall protection systems are used, then the concern of fall injury is addressed and ladders and stairways are not required. However, frequent access to the same location or by more than one employee will negate the finding that the access requirements are non-routine and a ladder or stairway may be required.

If we can be of any further assistance please contact Mr. Roy F. Gurnham or Dale R. Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 523-8136.


Patricia K. Clark, Director
Directorate of Compliance Programs