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.

May 27, 1999

Darin J. Paschall
Division Manager
Brand Scaffold Rental and Erection, Inc.
Huntington, WV Division
111 Thompson Road
Culloden, West Virginia 25510

Re: Whether attached scaffold ladders must extend above the scaffold platform; 29 CFR 1926.1053(b)(1)

Dear Mr. Paschall:

This is in response to your letter of July 16, 1998 requesting information on the requirements for scaffold ladders. You ask how far the top of a scaffold manufactured attachable ladder must extend above the platform. We apologize for the lateness of this response.

29 CFR 1926.451(e)(2) provides that attachable ladders for scaffolds must meet the requirements spelled out in 1926.451(e)(2)(i)-1926.451(e)(2)(vi). Portable ladders used for scaffold access must also meet the applicable requirements in 1926 Subpart X (one of those provisions, 1926.1053(b)(1), contains requirements for extending ladder side rails above the landing surface level). However, while portable ladders must meet the Subpart X requirements, the scaffold standard does not require that attachable ladders for scaffolds meet the Subpart X rules. Therefore, there is no OSHA requirement that attachable scaffold ladders extend above the platform.

This letter supersedes and cancels OSHA's March 12, 1997 letter to Reggie Copeland, signed by Roy F. Gurnham.

If you have any additional questions, please write to the Occupational Safety and Health Administration, [Office of Construction Standards and Guidance, Room N3468], 200 Constitution Avenue, N.W., Washington, D.C. 20210.


Russell B. Swanson, Director
Directorate of Construction