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.

October 27, 1992

Mr. R. C. Mocny,
Vice President
Engineering and Manufacturing
Patent Scaffolding Company
Executive Office
One Bridge Plaza
Fort Lee, New Jersey 07024

Dear Mr. Mocny:

This is in response to your letter of July 21 in which you request a clarification of the application of Subpart X -- Stairways and Ladders, to scaffold step unit towers and whether or not a 1976 letter of interpretation from the Occupational Safety and Health Administration (OSHA) is still valid. This is also in response to your follow-up letter of October 6 in which you provided additional information about your products.

The provisions of Subpart X -- Stairways and Ladders apply to scaffold step unit towers when they are used for access to locations other than scaffold platforms. As you know, 1926.1052(a)(1) requires such stairways to "have landings of not less than 30 inches in the direction of travel and extend at least 22 inches in width at every 12 feet or less of vertical rise." These requirements appear to be met by the configuration labeled "parallel construction" on page 11 of your publication titled Safety Rules and Instructions # 508R.

Of course, when scaffold step unit towers are used for scaffold platform access, then the requirements and interpretations of 1926.451[(e)(4)] apply during construction.

If you have any further questions, please do not hesitate to contact myself or [Mr. Noah Connell] of my staff at [(202) 219-7207].


Roy F. Gurnham, Esq., P.E.
Office of Construction and Maritime
Compliance Assistance