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.

March 18, 1994

Mr. Rached N. Karanouh, P.E.
Chief Engineer
Waco Scaffolding & Equipment
4545 Spring Road
Cleveland, Ohio 44131

Dear Mr. Karanouh:

This is in response to your January 24 letter in which you request a clarification of the Occupational Safety and Health Administration (OSHA) standard for stairways and ladders. I apologize for the delay of this response.

We have reviewed the information you, Mr. Puccinelli of Safway Steel Products, and Mr. Mocny of Patent Scaffolding provided and agree that application of the Subpart X criteria to towers would not result in towers being modified accordingly, but would result in their being used less frequently with an increased use of ladders which we believe are not as safe a means of access. Although the plain reading of the provisions of Subpart X indicates that they could apply to all stairway type access including scaffold towers, we agree that they should not be so applied. OSHA is currently taking the necessary administrative steps to clarify the standard. In the interim, it is the policy of OSHA to not apply Subpart X to scaffold stair towers. We appreciate your company's help in providing the information and comments necessary to aid us in that effort.

If you have any further questions, please do not hesitate to contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.


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

January 24, 1994

Mr. Roy Gurnham
O.S.H.A. Office of Construction &
Compliance Assistance
Room N. 3610
200 Constitution Ave. N.W.
Washington D.C. 20210

Dear Mr. Gurnham

As per our telephone conversation , this letter is to request a clarification of the scope of 29CFR part 1926 subpart-X Stairways And Ladders as it applies to stair units manufactured to be used as an integral part of the welded frame scaffolds system.

There are two Major concerns that arise in attempting to comply with the latest standards 1) The geometry of a 30" landing with a maximum slope not to exceed 50 the stairway requires a minimum bay width of 8'-0" to achieve a 6'-6" rise (see sketch attached ). Because of the industry's standard and over whelming practice of 7'-0" frame spacing we will no longer be able to provide a stair access to our customers. As you know stair access to scaffolding are safest and more preferred by the end users.

2) The industry standard has been a 7'-0" stairway (see attached copies) which does not seem to comply with the latest standards. Changing the existing inventory could run into a great cost to the industry with no apparent additional safety benefits.

Please review these two points and respond to me as soon as possible. I hope that you are able to view manufactured stairway units in the same manner as the manufactured ladders (reference your letter to Mr. Saleeby dated 10/1/1991, attached).

Thank you for your time and prompt response.

Best Regards

Waco Scaffolding & Equipment
Rached N. Karanouh, P.E; Chief Engineer