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Safe ladder access to scaffold platforms

Summary A contractor asked what counted as safe scaffold access. OSHA said attached portable ladders had to meet ladder rules and integral scaffold ladders could be acceptable if properly designed and spaced, while ordinary supports and walk-through frames were not ladder access. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1974-12-06
Date issued
December 6, 1974
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

December 6, 1974
TS75-20
Mr. Henry V. Carvill,
Asst. Secretary
Corporate Safety Director
Henry C. Beck Company
[Recipient address omitted]

Re: 29 CFR 1926.451(a)(13)

Dear Mr. Carvill:
Regarding your request of November 25, 1974 concerning "Equivalent safe access" to scaffolds, I submit the following comments.
Our National Office in Washington, D. C. has taken the position that if portable ladders are affixed to scaffolds, such ladders must meet the pertinent portable ladder requirements. Ladders built integral to scaffold frames are acceptable if the rungs are of equal length, uniform distances apart, and designed by the scaffold manufacturer as a ladder access for that scaffold. Rungs should be continuously over each other landing levels. Rung spacings up to a nominal 16 1/2" center to center would also be acceptable in providing a safe access. Ledger supports, walk through frames, masonry frames, sidewalk canopy frames, shallow or deep trussed frames and frames with similar designs are not acceptable for use as a ladder access.
The only landing platform requirement for scaffold ladders is in 29 CFR 1926.451(e) and restricted to application on manually propelled mobile scaffolds.
For safe access, landing should be provided at reasonable distances. Such distances can be equated to the maximum of 35' required by 29 CFR 1925.451(e). A ladder safety device that a person could rest against to catch his breath should be an acceptable alternative where a platform is not feasible.
On the subject of your reference to Review Commission decisions, I would like to add the comment that even though some decisions may be adverse to specific standards, this does not negate or revoke the standards in question.
If I may be of further assistance, feel free to contact me.
Sincerely yours,
C. R. HOLDER Associate Assistant
Regional Director for
Technical Support

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