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.

April 26, 2002

Ms. Ellen Letourneau
261 Maple Hill Avenue
P.O. Box 310732
Newington, CT 06111

This is in response to your November 13, 2001, letter to the Occupational Safety and Health Administration (OSHA). Your letter was delayed in reaching this office because mail addressed to the government is first sent to a facility that sanitizes it. We apologize for the delay in addressing your questions.

Your letter included diagrams and illustrations of your pre-production device, "Universal Winner Wheels," an aluminum telescoping wheel axle that clips on to products such as ladders to facilitate transporting the ladder [or other object]. You asked if your product would comply with OSHA standards.

OSHA is generally precluded from approving or endorsing specific products. The variable working conditions at job sites and possible alteration or misapplication of an otherwise safe piece of equipment could easily create a hazardous condition beyond the control of the equipment manufacturer. However, where appropriate, we try to give some guidance to help employers assess whether products are appropriate to use in light of OSHA requirements.

Question (1): Are there any OSHA standards that address the use of a temporarily attached set of wheels for the purpose of making it easier to move a ladder from one location to another?

You explained that the device carries labels warning that the wheel axle must be removed from a ladder prior to using the ladder. Based on the information submitted, as long as the use of the device does not deform or damage the ladder or put any stresses on it beyond those for which it was designed, and the device is removed from the ladder before the ladder is put to use as a means of employee access or as a working surface, neither the OSHA construction ladder standard (29 CFR Part 1926, Subpart X) nor the construction scaffold standard (29 CFR Part 1926, Subpart L) would prohibit the use of this product for this purpose.

Question (2): Are there any OSHA standards that address the use of this device to convert a ladder to a means of carrying loads?

You also ask if the device, when used properly, can be used as a vehicle for carrying light loads. We do not have specific standards that address worker-powered material transport devices. However, in most cases, such use would violate paragraph (b)(4) of §1926.1053, which is part of OSHA's ladder standards for the construction industry. It provides that "ladders shall be used only for the purpose for which they were designed." We know of no ladders designed for use as a means of transporting objects. In addition, §1926.1053(b)(3) states that "[l]adders shall not be loaded beyond the maximum intended load for which they were built, nor beyond their manufacturer's rated capacity." Use of a ladder as a transport for objects could easily result in its being overloaded, since ladders are not usually designed to withstand loads in a horizontal position.

You should also be aware that OSHA's general industry standards for portable ladders are 1910.23. These standards would cover the use of ladders for maintenance purposes. Since the letter was addressed to the Directorate of Construction, this letter focuses on OSHA's construction industry standards in Part 1926.

We hope you find this information helpful. If you need additional information, please do not hesitate to contact us by fax at: U.S. Department of Labor, OSHA, [Directorate of Construction, Office of Construction Standards and Guidance], fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.



Russell B. Swanson, Director
Directorate of Construction