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.

August 12, 1997

Mr. Bert L. Nelson
dba Q-2 Company-General Contractor
P. 0. Box 575
Prosser, Washington 99350

Dear Mr. Nelson:

Thank you for your letter of October 20, 1996, to the Occupational Safety and Health Administration (OSHA) concerning access steps or ladders for getting on and off a flatbed trailer. We apologize for the delay in responding to your letter.

Please be advised that OSHA does not have a specific standard requiring steps or ladders for getting on and off bed trailers. As you may know, on November 14, 1990, OSHA published its final rule covering the use of stairways and ladders used in the construction industry, 29 CFR 1926.1050 - .1060. The language of the requirement in §1926.1051(a) that a stairway or ladder be provided at all personnel points of access where there is a break in elevation of 19 inches or more, is broad enough to include access to vehicle platforms when used in construction. OSHA has determined, as a matter of enforcement direction, that it will not apply the standard to this situation.

The question of vehicles was not specifically considered during the Subpart X rulemaking. Vehicles were, however, excluded from coverage under the general fall protection requirement of Subpart M. Our enforcement position with respect to Subpart X is therefore consistent with the way vehicles are treated under Subpart M.

Thank you for your concern in Occupational Safety and Health.

Sincerely,

Roy F. Gurnham, P.E., J.D., Director
Office of Construction Standards
and Compliance Assistance