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Scaffold attachable ladder extension above platform

Summary A scaffold company asked whether a manufacturer-attached scaffold ladder must extend above the platform as a portable ladder must. OSHA said the scaffold standard has no such extension requirement for attachable ladders, although portable access ladders must follow the separate ladder rules. The letter expressly cancels an earlier OSHA answer.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1999-05-27
Date issued
May 27, 1999
Status
Active
This letter expressly supersedes and cancels OSHA's March 12, 1997 letter to Reggie Copeland.
Status last verified October 9, 2026

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May 27, 1999

Darin J. Paschall
Division Manager
Brand Scaffold Rental and Erection, Inc.
Huntington, WV Division
[Recipient address omitted]

Re: Whether attached scaffold ladders must extend above the scaffold platform; 29 CFR 1926.1053(b)(1)

Dear Mr. Paschall:

This is in response to your letter of July 16, 1998 requesting information on the requirements for scaffold ladders. You ask how far the top of a scaffold manufactured attachable ladder must extend above the platform. We apologize for the lateness of this response.

29 CFR 1926.451(e)(2) provides that attachable ladders for scaffolds must meet the requirements spelled out in 1926.451(e)(2)(i)-1926.451(e)(2)(vi). Portable ladders used for scaffold access must also meet the applicable requirements in 1926 Subpart X (one of those provisions, 1926.1053(b)(1), contains requirements for extending ladder side rails above the landing surface level). However, while portable ladders must meet the Subpart X requirements, the scaffold standard does not require that attachable ladders for scaffolds meet the Subpart X rules. Therefore, there is no OSHA requirement that attachable scaffold ladders extend above the platform.

This letter supersedes and cancels OSHA's March 12, 1997 letter to Reggie Copeland, signed by Roy F. Gurnham.

If you have any additional questions, please write to the Occupational Safety and Health Administration, [Office of Construction Standards and Guidance, Room N3468], 200 Constitution Avenue, N.W., Washington, D.C. 20210.

Sincerely,

Russell B. Swanson, Director
Directorate of Construction

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