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.

February 12, 1981

MEMORANDUM FOR:     JAMES W. LAKE
                   REGIONAL ADMINISTRATOR

ATTENTION:          JOHN GRANCHI
                   APA, OFFICE OF TECHNICAL SUPPORT

THRU:               JOHN B. MILES, JR.
                   FIELD COORDINATOR

FROM:               BRUCE HILLENBRAND
                   DEPUTY DIRECTOR, FEDERAL COMPLIANCE
                     AND STATE PROGRAMS

SUBJECT:            29 CFR 1926.450(b) and ANSI A14.4-1973

REFERENCE:          Memorandum, your office, dated January 20, 1981,
                   same subject.

We agree that the 3-inch by 6-inch lumber referred to in the last half of 29 CFR 1926.450(b)(8) is not normally available except by a special order. However, employers purchasing 3-inch by 6-inch special purpose lumber may build job-made ladders up to 30 feet in length.

29 CFR 1926.450(b)(9) allows double cleat ladders with 2-inch by 6-inch lumber side rails from 12 to 24 feet in length. Therefore, single cleat ladders with 2-inch by 6-inch lumber side rails up to 24 feet in length, as permitted by ANSI A14.4-1973, are not considered in violation in accord with our de minimus policy. Only the special order 3-inch by 6-inch lumber used for side rails may exceed the 24 feet maximum. The reference in our standard to the 3-inch by 6-inch lumber will be considered for deletion when Subpart L, Ladders and Scaffolding, is modified in the future.