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Safe access while assembling or dismantling scaffolds

Summary A construction company asked five questions about access during scaffold assembly and dismantling. OSHA said continuous ladder access was not required during those tasks, but other safe access was; manufacturer-designed scaffold end frames could count when their rungs formed a continuous path with the specified spacing. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1983-02-25-0
Date issued
February 25, 1983
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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
Topics
Workplace Safety OSHA 1926 Scaffolds Ladders Access
Source
View the official document

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

February 25, 1983

W.D. Braswell, C.S.P.
Vice President, Safety
A.A. Beiro Construction Company, Inc.
[Recipient address omitted]

Dear Mr. Braswell:

This is in response to your letter of February 8, 1983, requesting a clarification of 29 CFR 1926.451(a)(13). The response to your five points is as follows:

  1. It is not practical or intended that employers provide ladder access at all times for employees assembling or dismantling scaffold components; however, other safe access must be provided.

  2. End frames are acceptable for access if the rungs are designed by the scaffold manufacturer as an access ladder, and they are arranged in such a way that they form a continuous series of steps from the scaffold top to its bottom. Maximum spacing between rungs shall not exceed 16 1/2 inches.

  3. Portable wood or metal ladders used to provide safe access must comply with 29 CFR 1926.450(a)(3) and (4).

  4. The fixed ladder standards do not apply to scaffolds.

  5. The ladder standards do not apply to scaffold structures when they are built into the scaffold components.

If I may be of further assistance, please feel free to contact me.

Sincerely,
John K. Barto Chief,
Division of Occupational Safety Programming

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