Letter of Interpretation for Scaffold FAQ #4

Standards Interpretation and Compliance Letters

Requirements for attachable ladders used for scaffold access.

Record Type: Interpretation
Standard Number: 1926.451(e)(2)
Subject: Requirements for attachable ladders used for scaffold access.
Information Date: 05/27/1999

May 27, 1999

Darin J. Paschall
Division Manager
Brand Scaffold Rental and Erection, Inc.
Huntington, WV Division
111 Thompson Road
Culloden, West Virginia 25510

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)-(vi). Portable ladders used for scaffold access must also meet the applicable requirements in 1926 subpart X (one of those provisions, 29 CFR 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 Compliance Assistance
Room N3621
200 Constitution Avenue, N.W.
Washington, D.C. 20210.

Sincerely,

Russell B. Swanson, Director
Directorate of Construction