Tools on stepladder tops and colors used on construction sites

June 13, 2006

Stanley E. Draper

[Recipient address omitted]

Re: Whether it is permissible to leave tools in the holes of the top plate of a self-supporting ladder; whether employers are permitted to develop their own color coding system at a construction site

Dear Mr. Draper:

This is in response to your letter dated October 13, 2005, to the Occupational Safety and Health Administration (OSHA). We apologize for the delay in providing this response.

We have paraphrased your question as follows:

Scenario: A self-supporting ladder has holes in its top plate; the holes are designed by the ladder manufacturer to serve as holders for tools; the user's storage of tools in these holes is consistent with the manufacturer's instructions for use of the ladder, and is within the ladder's designed capacity.

Question (1): In this scenario, do any OSHA construction requirements prohibit leaving such hand tools lodged in these holes when a worker is, even briefly, not on the ladder?

Answer: With respect to the scenario you describe, there are no OSHA standards that prohibit keeping such tools in these storage holes, either while the worker is on or off the ladder.[1]

Question (2): We use colored tape to designate areas on the floor for various non-safety related purposes. For example, we use red tape to indicate where trash cans are to be placed and yellow tape to indicate where miscellaneous moveable items are to be placed. Is there an OSHA construction standard that requires these colors to be used solely for certain safety-related purposes — is red reserved for fire equipment or flammable materials; is yellow reserved for tripping hazards?

Answer: Title 29 CFR Part 1926 Subpart G (Signs, Signals, and Barricades) contains color requirements for certain types of signs on construction sites. Specifically, §1926.200 includes the following provisions:

(b) Danger signs. * * *

(2) Danger signs shall have red as the predominating color for the upper panel; black outline on the borders; and a white lower panel for additional sign wording.

(c) Caution signs. * * *

(2) Caution signs shall have yellow as the predominating color; black upper panel and borders: yellow lettering of "caution" on the black panel; and the lower yellow panel for additional sign wording. Black lettering shall be used for additional wording.

(d) Exit signs. Exit signs, when required, shall be lettered in legible red letters, not less than 6 inches high, on a white field and the principal stroke of the letters shall be at least three-fourths inch in width.

(e) Safety instruction signs. Safety instruction signs, when used, shall be white with green upper panel with white letters to convey the principal message. Any additional wording on the sign shall be black letters on the white background.

(f) Directional signs. Directional signs, other than automotive traffic signs specified in paragraph

(g) of this section, shall be white with a black panel and a white directional symbol. Any additional wording on the sign shall be black letters on the white background.

As can be seen from these provisions, certain types of signs are required to have a particular color scheme. However, these requirements do not state that the use of these colors is precluded for other purposes.

If you need additional information, please do not hesitate to contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Compliance Assistance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.

Sincerely,

Noah Connell, Acting Director

Directorate of Construction

[1] If there have been instances of tools falling from these holders at your workplace, such instances may indicate the need for hard hats pursuant to 29 CFR 1926.100 (head protection).