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Job-made ladders versus manufactured portable ladders

Summary A requester proposed selling disposable ladders built to job-made ladder specifications. OSHA said the job-made rules applied to ladders actually built for temporary construction use; a manufactured ladder used as a portable ladder still had to meet the portable-ladder requirements. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1978-11-06
Date issued
November 6, 1978
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

29 CFR 1926.450(a)(3)

November 6, 1978
Mr. Richard L. Collins
[Recipient address omitted]
Dear Mr. Collins:
This is in response to your letter dated September 28, 1978, requesting an official interpretation of 29 CFR 1926.450(a)(3).
The job-made ladders built to the requirements of 29 CFR 1926.450(b) are intended for temporary use on construction and demolition operations. A job-made ladder is entirely different from a portable wood ladder and would never be required to meet the requirements referenced in 29 CFR 1926.450(a)(3) of the construction Safety and Health Regulations.
Your concept of a manufactured low cost, disposable ladders constructed to specifications exceeding those in 1926.450(b) but not meeting the requirements of 29 CFR 1926.450(a)(3) for portable ladders when used as a portable ladder would be in violation of 29 CFR 1926.450(a)(3). Any employer providing a shoddy on the job-built ladder not meeting the requirements of 29 CFR 1926.450(b) will be cited in violation of the aforementioned standard. Special purpose ladders do meet applicable design requirements but do not satisfy all specification criteria referenced in 29 CFR 1926.450(a)(3) because of the special requirements and use.
The proposed standards for revocation in 29 CFR 1910.25 have now been revoked and a ladder built to the specifications of 29 CFR 1926.450(b) does not meet the requirements of 29 CFR 1910.25 for portable ladders.
Thank you for your interest in occupational safety and health. If I may be of any further assistance, please feel free to contact me.
Sincerely,
John K. Barto, Chief
Division of Occupational
Safety Programming

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