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Stairway and ladder rule for scaffold access ladders

Summary A scaffolding institute asked whether construction stairway and ladder rules applied to ladders used for scaffold access. OSHA said the cited subpart did not cover ladders specifically made for scaffold access, but did cover general-purpose portable and job-made ladders used that way. OSHA marks this letter archival.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-10-01-6
Date issued
October 1, 1991
Status
Archived by the agency
This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review.
Status last verified October 9, 2026

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This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

October 1, 1991

Ms. Margaret L. Rothschild
Scaffolding, Shoring & Forming Institute, Inc.
[Recipient address omitted]

Dear Ms. Rothschild:

This is in response to your letter of May 30, 1991, in which you request a clarification of the scope of 29 CFR Part 1926, Subpart X-Stairways and Ladders as it applies to ladders used with scaffolds. We apologize for the delay in responding to your inquiry.

Subpart X does not apply to ladders which are specifically manufactured for scaffold access and egress. However, Subpart X does apply to job-made and manufactured portable ladders which are intended for general purpose use and which are then used for scaffold access and egress.

Examples of general purpose ladders are those manufactured to meet the following American National Standards Institute (ANSI) publications: ANSI A14.1 (portable wood ladders), ANSI A14.2 (portable metal ladders), ANSI A14.4 (job-made ladders) and ANSI A14.5 (portable reinforced plastic ladders).

If we may be of further assistance, please do not hesitate to contact either Mr. Roy F. Gurnham or Mr. Dale Cavanaugh at (202) 523-8136.

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

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