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 #200801220-8196

Re: Using a stepladder as a non-self-supporting ladder

Question: 29 CFR 1926.1053(b)(4) requires ladders to be used only for the purpose for which they were designed. Some manufacturers have indicated a concern that a self-supporting ladder might slip out and cause someone to fall if it is used as a non-self-supporting ladder.

Scenario: A stepladder (which is a type of' self-supporting ladder) is used as a non-self-supporting ladder, but the bottom of the ladder is either "footed" (that is, another person keeps their foot on the bottom to keep the ladder from slipping) or the ladder is tied off at the bottom to prevent the bottom from slipping out.

Would the use of a stepladder as described above violate 29 CFR 1926.1053(b)(4)? If so, would such use be a de minimis violation?

Answer: In 29 CFR 1926 Subpart X, 1926.1053(b)(4) states:

 

 

Ladders shall be used only for the purpose for which they were designed. [Emphasis added]

Thus, using a stepladder as a non-self-supporting ladder would violate §1926.1053(b)(4) if the ladder were not designed for that purpose. The particular design of a stepladder varies from manufacturer to manufacturer. Therefore, whether or not the scenario you describe constitutes a violation of §1926.1053(b)(4) would depend on whether such use is consistent with the purpose intended by the manufacturer.

It is our understanding that self-supporting ladders, including stepladders, typically, are not designed to be used as non-self-supporting ladders unless otherwise indicated by the manufacturer. For example, note that paragraph 8.3.1.2 of ANSI A14.1-1982 and ANSI-ASC A14.1-2007 state that, "[s]elf-supporting ladders shall not be used as single ladders or in the partially closed position" [emphasis added].1 Note, also, that ANSI-ASC A14.1-2007 defines "single ladder" as a "non-self-supporting portable ladder, nonadjustable in length, consisting of one section." Statements from manufacturers indicating a concern that a self-supporting ladder might slip out and cause someone to fall, if used as a non-self-supporting ladder, would be consistent with these ANSI provisions.

Typically, having a coworker hold the ladder, or using rope to attempt to restrain the ladder at its base, would not be considered substitutes for this requirement. We note that, for example, slip-out is not the only hazard that can result from using a ladder differently than in accordance with its design.

Furthermore, 1926.1053(a)(2) states:

Ladder rungs, cleats, and steps shall be . . . level . . . when the ladder is in position for use. [Emphasis added]

Stepladders are typically designed so that the rungs are level when the ladder is in the open and locked position and the ladder is placed on a stable and level surface. Consequently, it is likely that positioning a stepladder for use as a non-self-supporting ladder would result in the ladder's rungs being out-of-level, which would violate 1926.1053(a)(2).

Sincerely,



Richard E. Fairfax, Acting Director
Directorate of Construction

 

 

 

 

1 Note that the preamble to 1926.1053(b)(4), in Volume 55 of the Federal Register at page 47678 (November 14, 1990), states that paragraph (b)(4) is based, in part, on paragraph 8.3.1 of ANSI A14.1-1982 and paragraph 8.3.1 of ANSI A14.2-1982, although those ANSI provisions were not incorporated into Subpart X. [back to text]