June 2, 1998

Mr. Gregory C. Clemens
Roofmaster Products Company
P. O. Box 6339
Los Angeles, CA 90063-0309

Re: 1926.500-503; 1926.552; 1926.1053

Dear Mr. Clements:

This is in response to your letter dated October 4, 1995, requesting an interpretation of the Occupational Safety and Health Administration (OSHA) standards addressing ladders used to support a hoisting wheel. Your letter references the use of a Ladder Master Hoisting Wheel, and the need to adhere to the regulations for ladder use while involved in lifting materials with this device.

Ladders are required to be secured to prevent accidental displacement when employees are using them on unstable, slippery or non level surfaces. However, when using a ladder to lift materials with a hoisting wheel, employees would not be using the ladder for climbing and therefore would not be subjected to ladder use requirements.

When involved in this lifting activity, the ladder would not be considered a hoist for the purposes of OSHA's hoisting regulations and would therefore not be subject to the provisions of Subpart N-Cranes, Derricks, Hoists, Elevators, and Conveyors. However, those employees exposed to fall hazards during lifting activities must comply with the applicable fall protection requirements in accordance with 29 CFR 1926.500-503, (e.g. safety monitor for low sloped roofs).

We agree, if used properly and within manufacturer's guidelines, this ladder hoisting wheel could reduce or eliminate injuries from lifting heavy loads while climbing ladders.

Thank you for your interest in job site safety and health issues and if we can be of any further assistance, please write to:

Directorate of Construction-OSHA
Office of Construction Standards and
Compliance Assistance, Rm. N3621
200 Constitution Avenue, N.W.- Rm. N3621
Washington, D.C. 20210

Sincerely,

Russell B. Swanson, Director
Directorate of Construction



October 4, 1995

Mr. Roy F Gurnham
U. S. Department of Labor
Occupational Safety and Health Administration
Washington. D.C. 20210

Re: Ladders as a hoist

Dear Mr. Gurnham:

A product called the Ladder Master Hoisting Wheel has been sold into the construction trades for decades. It is placed on the inside rungs (toward the building) for hoisting light loads to the roof edge.

The worker on the roof grasps the handle end and pushes the ladder outward to his arms length (the handle is 24" long). The worker on the ground, standing outside of the rungs so he is not under the load, pulls the load up using a 3/4" manila rope.

Ladder mounted hoisting wheels are manufactured for both round rung and flee rung ladders. Warning labels indicate that they are not to be used for loads exceeding the rating of the ladder

Here is our problem:

A roofer in the Carolinas phoned today to say that he was confused. He acknowledges that he must tie-off his ladder when his workers use it to more from one level to another. When he then wants to use his ladder as a hoist, using the ladder mounted hoisting wheel, he cannot comply with this provision since he could not raise the load.

When he installs the hoisting device on the ladder, it is no longer a ladder, it is now a hoist. At this point. his hoist should be subject to safety provisions other than the ladder tie-off rule.

Perhaps at this point, he would be subject to 29 CFR 1926.501(b)(3) under the duty to have fall protection in a hoist area.

The use of these wheels is widespread. As the manufacturer, we would like lo issue proper information and if needed create new safety labels for these products. The use of ladder mounted hoisting wheels saves many a worker from back injury, while allowing them to focus on the job of climbing a ladder, not carrying a load up or down the ladder.

Thank you for your attention to this issue.

Kind regards,

Larry Clemens