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 http://www.osha.gov.

April 18, 2014

Mr. Dwight Parker Sr.
301 Irvine Turner Blvd.
Apt. 1128
Newark, NJ 07108

Dear Mr. Parker:

This is in response to your letter dated January 27, 2014, to the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to OSHA's Directorate of Enforcement Programs for response. You had questions about OSHA's policy on ladders, and specifically about rungs for ladders on bunk beds and fire escapes.

Your paraphrased question and our reply follow:

Question: Are ladders of any type allowed to have round rungs as the primary means of ascending that ladder? This request concerns ladders on bunk beds, fire escapes, etc.

Response: OSHA's standards and guidance on ladders address only workplace situations. Although your inquiry does not seem to address a specific workplace situation, General Industry standards 29 CFR 1910.27(b)(1)(i), (ii), and (iii) on diameter, distance, and size requirements; and Construction standard 29 CFR 1926.1053(a)(2) on spacing requirements for rungs on ladders, may be useful for you. OSHA does not prohibit round rungs on ladders. However, rungs must be parallel, level, and uniformly spaced when the ladder is in position for use. Additionally, rungs or steps on both portable and fixed ladders must be shaped in a way to minimize slipping. For information on ladder safety for fire escapes, please see OSHA's instruction on the use of fixed ladders in emergency situations: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1754. In addition, the National Fire Protection Association may have relevant information on fire escape ladders.

The following links to OSHA's stairway and ladder rules, general ladder safety information, and OSHA's frequently asked questions may be useful for you as well:

Thank you for your interest in occupational safety and health. We hope you find this information helpful. To ensure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov/. If you have further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,
Thomas Galassi, Director
Directorate of Enforcement Programs