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.



December 6, 2004

Mr. James E. Vaughan
Today's Resources, Inc.
5690 Clyde Moore Drive
Groveport, OH 43125

Re: Whether automatically retractable rest platforms used with self-retracting lifelines meet the requirements for fixed ladder safety equipment; §1926.1053(a)(19)

Dear Mr. Vaughan:

This is in response to your letter dated July 20, 2004, to the Occupational Safety and Health Administration (OSHA). You ask about requirements in the stairways and ladders standard, 29 CFR Part 1926 Subpart X, regarding the use of a retractable landing platform on a fixed ladder that is integral to a scaffold. We apologize for the delay in responding to your request.

We have paraphrased your questions as follows:

Question: Section 1926.1053(a)(19) requires fixed ladders to be equipped with one of several types of devices where employees climb in excess of 24 feet. A manufacturer uses a retractable rest platform on the support towers of its work platform in combination with a self-retracting lifeline. The rest platform folds out for use and, when not in use, automatically retracts.


Automatically retractable rest platform on support tower of work platform used in combination with self-retracting lifeline showing 2 views: rest platform folded out in used position and in retracted position.


Would use of these devices satisfy this requirement?

Answer: Title 29 CFR 1926.1050(b) defines a fixed ladder as "a ladder that cannot be readily moved or carried because it is an integral part of a building or structure." Section 1926.1053(a)(19) states:

Where the total length of a climb equals or exceeds 24 feet (7.3 m), fixed ladders shall be equipped with one of the following:
(i) Ladder safety devices; or
(ii) Self-retracting lifelines, and rest platforms at intervals not to exceed 150 feet (45.7 m); or
(iii) A cage or well, and multiple ladder sections, each ladder section not to exceed 50 feet (15.2 m) in length. Ladder sections shall be offset from adjacent sections, and landing platforms shall be provided at maximum intervals of 50 feet (15.2 m).



This paragraph allows employers to choose among these methods of ensuring employees will be able to safely complete an ascent/descent of 24 or more feet on a fixed ladder. The method specified in §1926.1053(a)(19)(ii) requires the use of both rest platforms at intervals no greater than 150 feet and a self-retracting lifeline.

The standard does not specify whether the rest platform must be permanently in place or if it may be retractable. As long the platform intervals do not exceed 150 feet, the deployment/retraction mechanism works properly, and a self-retracting lifeline is used, the retractable platform would meet this requirement.

If you need additional information, please 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