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Safe access to tubular steel scaffolds

Summary A scaffold manufacturer asked what counted as safe access to tubular scaffolds. OSHA said stairs, suitable ramps or runways, and ladder-like configurations could qualify, but the submitted variable-rung design appeared out of compliance. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1977-12-15
Date issued
December 15, 1977
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 15, 1977
Mr. James Somero
Vanguard Manufacturing Inc.
[Recipient address omitted]
Dear Mr. Somero:
This is in response to your letter of October 26, 1977, regarding an interpretation of the standards regulating access for tubular steel scaffolding.
In 29 CFR 1926.451(a)(13) the standard states: "An access ladder or equivalent safe access shall be provided." The "equivalent safe access" to any scaffolding may include permanent or temporary stairways, suitable ramps or runways, or configurations that are similar to ladders as described in 29 CFR 1926.450 ladders; the main requisite being that reasonable safety of employees is assured when using such means of access and egress.
If would appear from your enclosed drawing that your ladder attached to the scaffold frame is not in compliance with 29 CFR 1926.451(a)(13). However, consideration of this variable rung spacing type of access is being reviewed at this time by the Office of Standards Development.
Thank you for your concern and continued interest in occupational safety and health.
Sincerely,
John K. Barto, Chief
Division of Occupational
Safety Programming

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