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.

 


Letter# 20070307-7544

Re: The use of cable hook assemblies, pole grip assemblies, or adjustable levelers on fiberglass extension ladders used in construction

Question: My question concerns ladder attachments: a cable hook or pole grip assembly, which is used to secure extension ladders to telephone poles or other similar objects, and an adjustable leveler, which is a device that attaches to a leg of the ladder and levels the ladder when it is placed on uneven surfaces. Is the use of these attachments on a fiberglass extension ladder permissible?

Answer: By its terms, 29 CFR 1926 Subpart X does not specifically prohibit the use of the add-on cable hook assemblies, pole grip assemblies, or adjustable levelers that you describe. Nevertheless, an employer that uses this equipment must comply with all Subpart X requirements. Pertinent requirements include, but are not limited to, the following:

29 CFR 1926.1053(b)(1):

 

When portable ladders are used for access to an upper landing surface, the ladder side rails shall extend at least 3 feet (.9 m) above the upper landing surface to which the ladder is used to gain access; or when, such an extension is not possible because of the ladder's length, then the ladder shall be secured at its top to a rigid support that will not deflect, and a grasping device, such as a grabrail, shall be provided to assist employees in mounting and dismounting the ladder. In no case shall the ladder extension be such that ladder deflection under a load would, by itself, cause the ladder to slip off its support.

29 CFR 1926.1053(b)(3):

Ladders shall not be loaded beyond the maximum intended load for which they were built, nor beyond their manufacturer's rated capacity.

29 CFR 1926.1053(b)(6):

Ladders shall be used only on stable and level surfaces unless secured to prevent accidental displacement.

29 CFR 1926.1053(b)(7):

Ladders shall not be used on slippery surfaces unless secured or provided with slip-resistant feet to prevent accidental displacement. Slip-resistant feet shall not be used as a substitute for care in placing, lashing, or holding a ladder that is used upon slippery surfaces including, but not limited to, flat metal or concrete surfaces that are constructed so they cannot be prevented from becoming slippery.

29 CFR 1926.1053(b)(9):

The area around the top and bottom of ladders shall be kept clear.

29 CFR 1926.1053(b)(10):

The top of a non-self-supporting ladder shall be placed with the two rails supported equally unless it is equipped with a single support attachment.

 

 

In particular, as noted above, under 1926.1053(b)(6), if a ladder is not on a "level surface," it must be "secured to prevent accidental displacement." With respect to an adjustable leveler, in some instances, its use may be the equivalent of a ladder being placed on a level surface. However, we cannot say that this would always be the case, since there are numerous factors that could diminish its effectiveness. The type of surface supporting the ladder, extent to which the surface is not level and/or uneven, and capability of the device are examples of such factors.

Also, as noted above under 1926.1053(b)(3), use of the ladder in a manner that would exceed its intended/rated capacity is prohibited. If use of an attachment would impose loads on the ladder that would result in exceeding its intended or rated capacity, the use of the attachment would be prohibited.

Richard E. Fairfax, Acting Director
Directorate of Construction