January 3, 2012
Brian D. Monistere, P.E.
Professional Safety Services
Post Office Box 321029
Flowood, MS 39232
Dear Mr. Monistere:
Thank you for your March 18, 2011, letter to the Occupational Safety and Health Administration (OSHA), Directorate of Standards and Guidance. Since it involves construction issues, it has been forwarded to the Directorate of Construction for response.
In your letter, you asked if employees stand on the top step of a trestle ladder, does it constitute a violation of 29 CFR 1926.1053(b)(13) which states that "the top step of a stepladder shall not be used as a step."
For your information, OSHA defines a trestle ladder as "a self supporting ladder, adjustable length, consisting of a trestle ladder base and a vertically adjustable extension, with a suitable means of locking the ladders together."
Your letter raises two questions for which the answers are below.
Question 1: When a trestle ladder is used as a stepladder does 29 CFR 1926.1053(b)(13) apply?
Answer: Yes. If a trestle ladder can be used such that when configured, its vertically extended section does not extend at least "two rungs beyond the center section of the ladder", then OSHA would consider its use the same as a stepladder.
Question 2: When a trestle ladder is used with its trestle extended "such that two rungs are beyond the center section of the ladder "does 29 CFR 1926.1053(b)(13) apply?
Answer: No. If the vertical extension is extended "two rungs beyond the center section of the ladder" required by the manufacturer, then the ladder would fall out of the category of a stepladder, thus the standard, 29 CFR 1926.1053 (b)(13), would not apply.
In addition, the use of a trestle ladder must comply with the general "Use" section under 1926.1053(b) and "Training Requirements" section under 1926.1060. OSHA also recommends that the employer review the American National Standard Institute (ANSI) standards which address extension trestle ladders such as:
- ANSI A14.1 (Portable Wood Ladders)
- ANSI A14.2 (Portable Metal Ladders)
- ANSI A14.5 (Portable Reinforced Plastic Ladders)
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our 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 and to view all OSHA's standards, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.
James G. Maddux, Director
Directorate of Construction