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.

June 6, 2024

Corry Gruwell
Safety Director
Momentiv
3012 East 1st Street
Duluth, MN 55812

Dear Mr. Gruwell:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding requirements of mobile ladder stand platforms used to access the tables of computer numerical control (CNC) machines that your company uses. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased scenario, questions, and our responses are provided below.

Scenario: A mobile ladder stand platform with steps will be constructed to access multiple CNC machine tables at a height of 40 inches measured from the floor.

Question 1: What is the rise height, tread depth, and width requirements of mobile ladder stand platform steps?

Response: The requirements for mobile ladder stand platforms are contained in 29 CFR § 1910.23(e), Mobile Ladder Stands and Mobile Ladder Stand Platforms in addition to requirements specified in paragraph (b) of this section which covers all ladders. Specifically, § 1910.23(e)(1)(i) requires that the mobile ladder stands and platforms have "a step width of at least 16 inches (41 cm)." Additionally, § 1910.23(e)(3)(i) requires the steps of mobile ladder stand platforms meet the requirements contained in § 1910.23(e)(2)(i) which states, "(s)teps are uniformly spaced and arranged, with a rise of not more than 10 inches (25 cm) and a depth of not less than 7 inches (18 cm). The slope of the step stringer to which the steps are attached must not be more than 60 degrees, measured from the horizontal."

Question 2: Does the landing area need to be 30 inches in the direction of travel?

Response: No. The 30-inch requirement in the direction of travel applies only to the stairways covered under 29 CFR § 1910.25.

Question 3: Do mobile ladder stand platforms, measured 40 inches or less in height from the ground, require a mid-rail or a top rail?

Response: No. A top rail and a midrail are not required for mobile ladder stand platforms less than 4 feet in height from the ground. Handrails with a vertical height of at least 36 inches (91 cm) and midrails are required in the platform area of mobile ladder stand platforms with a platform height of 4 to 10 feet (1.2 m to 3 m). (§1910.23(e)(3)(ii)). All mobile ladder stand platforms with a platform height above 10 feet (3 m) are required to have guardrails1 and toeboards2 on the exposed sides and ends of the platform. (§1910.23(e)(3)(iii)).

Question 4: Does the top rail on a mobile ladder stand platform need to withstand 200lbs of force?

Response: Yes, § 1910.29(b)(3) provides guardrail systems must be "capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied in a downward or outward direction within 2 inches (5 cm) of the top edge, at any point along the top rail."

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, such letters may be affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have any questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,

Scott C. Ketcham, Acting Director
Directorate of Enforcement Programs

1 Guardrail requirements are contained in 29 CFR 1910.29(b).

2 Toeboard requirements are contained in 29 CFR 1910.29(k).