- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
January 20, 1981
MEMORANDUM FOR: BRUCE HILLENBRAND
Director, Office of Federal
Compliance and State Programs
THROUGH: JOHN MILES, JR.
Director, Office of Field Coordination
FROM: JOHN A. GRANCHI,
ARA, Office of Technical Support
SUBJECT: 29 CFR 1926.450(b) and ANSI A14.4-1973
Your attention is invited to 29 CFR 1926.450(b)(8) detailing the size of lumber to be utilized for side rails of job-made ladders:
"(8) 2-inch by 4-inch lumber shall be used for side rails of single cleat ladders up to 16 feet long; 3-inch by 6-inch lumber shall be used for single cleat ladders from 16 to 30 feet in length."
The 3-inch by 6-inch lumber alluded to in the last half of the paragraph is not available except by special order through saw mills. This particular size lumber is not now, nor has it ever been, available at conventional lumber outlets.
Additionally, ANSI Standard A14.4-1973, paragraph 4.4, which refers the reader to Tables 2 and 3, excludes 3"x6" lumber from use.
There is another conflict in the same above referenced standards in that 1926.450(b)(8) allows job-made ladders up to 30 feet in length while the ANSI Standard 4.2 as well as Tables 2 and 3 allow a maximum length of 24 feet.
As the issue outlined above is national in scope and impacts the standards of the State Plan states, request that the National Office issue an interpretation and/or guidance to resolve this apparent anomaly in our standards.