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OSHA 1926.1051

Stairways and ladders access requirements

1926 Subpart X

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1051(a), when must an employer provide a stairway or ladder at a personnel point of access?

A stairway or ladder must be provided whenever there is a vertical break in elevation of 19 inches (48 cm) or more and no ramp, runway, sloped embankment, or personnel hoist is provided. See the requirement in 1926.1051(a).

  • Measure the vertical difference between walking surfaces; if it is 19 inches (48 cm) or more and none of the listed alternatives (ramp, runway, sloped embankment, personnel hoist) exists, provide a stairway or ladder.
  • This requirement ensures safe access and exit for employees between levels.

Under 1926.1051(a), how do you measure the "break in elevation of 19 inches (48 cm) or more" that triggers the stairway/ladder requirement?

You measure the vertical distance between the two walking surfaces; if that vertical difference is 19 inches (48 cm) or more, a stairway or ladder is required when no ramp, runway, sloped embankment, or personnel hoist is provided. See 1926.1051(a).

  • The measurement is vertical (straight up and down), not along a slope or ramp.
  • If an approved ramp, runway, sloped embankment, or personnel hoist exists and is usable, a stairway or ladder is not required for that break in elevation.

Under 1926.1051(a)(1), can employees use a temporary spiral stairway to access a work area?

No; employees may not use spiral stairways that are not a permanent part of the structure on which construction work is being performed. See 1926.1051(a)(1).

  • The rule prohibits non-permanent spiral stairways because they often do not meet safe access characteristics expected of permanent stairways.
  • A spiral stairway that is an actual permanent component of the structure (built into the building) would not be barred by this sentence.

Regarding 1926.1051(a)(2), when must a double-cleated ladder or two separate ladders be provided?

A double-cleated ladder or two or more separate ladders must be provided when ladders are the only means of access or exit for a working area used by 25 or more employees, or when a ladder must serve simultaneous two-way traffic. See 1926.1051(a)(2).

  • If a single ladder is the only access/egress for 25+ workers, provide either a ladder with double cleats (to allow safe two-way use) or at least two separate ladders.
  • If workers must pass each other (two-way traffic) on a ladder, provide a ladder arrangement that allows safe two-way movement as required by the same paragraph.

Under 1926.1051(a)(2), what is meant by a "double-cleated ladder" and when is it used?

A double-cleated ladder is provided as one option to allow safe two-way movement or to serve many employees when ladders are the only access; it is used when ladders are the only means of access or exit for 25 or more employees or to accommodate simultaneous two-way traffic. See 1926.1051(a)(2).

  • The standard offers the double-cleated ladder as an alternative to providing two separate ladders; it provides additional footing/cleats to allow two-way use.
  • Employers should ensure whatever ladder solution they choose is appropriate for the number of workers and the traffic conditions present.

Under 1926.1051(a)(3), what must an employer do if a building has only one point of access between levels and that access becomes obstructed by work or equipment?

If a building or structure has only one point of access between levels and that point is restricted by work or equipment so that free passage is not possible, the employer must provide and use a second point of access. See 1926.1051(a)(3).

  • The single existing access must be kept clear to permit free passage; when it cannot be kept clear, a second access point is required before work proceeds that blocks the first.
  • This is to ensure safe egress and movement of employees at all times.

Under 1926.1051(a)(3), how should an employer keep a single point of access "clear to permit free passage of employees"?

An employer must maintain the single access route so employees can move through it without obstruction; if job activities or equipment would block free passage, the employer must provide and use a second point of access. See 1926.1051(a)(3).

  • "Keep clear" means unobstructed by tools, materials, equipment, or work tasks that prevent employees from passing.
  • If work tasks temporarily block the route, prior planning must provide an alternate, usable access before the blockage occurs.

Under 1926.1051(a)(4), what is required when a building has two or more points of access between levels?

When a building or structure has two or more points of access between levels, the employer must keep at least one point of access clear to permit free passage of employees. See 1926.1051(a)(4).

  • Employers may temporarily use or block one access point for work, but they must ensure at least one other access remains unobstructed for safe movement and egress.
  • This provides redundancy so employees are not trapped or delayed in emergencies.

Under 1926.1051(b), when must stairway and ladder fall protection systems be provided and installed?

Employers must provide and install all stairway and ladder fall protection systems required by the subpart and comply with other pertinent requirements before employees begin the work that necessitates their use. See 1926.1051(b).

  • Fall protection systems that are required for stairways and ladders must be in place prior to starting the tasks that require them.
  • This places the responsibility on the employer to plan and install fall protection in advance, not reactively after work starts.

Under 1926.1051, if a ramp or sloped embankment is provided, is a ladder or stairway still required for a 19-inch elevation change?

No; if a ramp, runway, sloped embankment, or personnel hoist is provided and usable for the break in elevation, a separate stairway or ladder is not required for a 19-inch (48 cm) or greater elevation change. See 1926.1051(a).

  • The presence of an acceptable alternative access method (ramp, runway, sloped embankment, personnel hoist) satisfies the access requirement for that elevation difference.
  • Employers should ensure the alternate method is safe and accessible for employees who must use it.

Under 1926.1051, does the rule apply to both access and exit points at work areas?

Yes; the rule applies to personnel points of access and exit—stairways or ladders must be provided where there is a 19-inch (48 cm) or more elevation break and no acceptable alternative is provided. See 1926.1051(a).

  • The standard is written to ensure safe movement both into and out of work areas, not just entry.
  • Employers must consider both directions when evaluating access and egress needs.

Under 1926.1051(a)(2), if 24 employees work in an area served only by ladders, must the employer provide double-cleated ladders or two ladders?

No; the specific threshold in 1926.1051(a)(2) is 25 or more employees. If only 24 employees use the area, the double-cleated ladder or two separate ladders requirement does not automatically apply, though employers must still provide safe access and may need to evaluate other hazards. See 1926.1051(a)(2).

  • Even below the numeric threshold, employers should consider traffic patterns and whether two-way movement will occur; if simultaneous two-way traffic will occur, provide an appropriate two-way ladder solution regardless of employee count.
  • Safety planning and hazard assessment remain the employer's responsibility.

Under 1926.1051, if work requires workers to move materials up and down between levels, does the standard require a separate stairway or ladder for material handling?

The standard requires stairways or ladders at personnel points of access for employee movement when the elevation break is 19 inches (48 cm) or more and no acceptable alternative exists; it does not separately mandate distinct ladders solely for materials but employers must ensure safe access and comply with other applicable material handling or scaffold rules. See 1926.1051(a).

  • If material handling impedes free passage of the access point, the employer must provide an alternate access so employees can pass safely, per 1926.1051(a)(3).
  • Other OSHA standards (for example, scaffold or mechanical hoist requirements) may apply to moving materials and should be consulted when materials are being raised or lowered.

Under 1926.1051, are employers allowed to delay installing required ladder or stairway fall protection systems until after employees start working?

No; employers must provide and install all stairway and ladder fall protection systems required by the subpart and comply with other pertinent requirements before employees begin the work that necessitates their use. See 1926.1051(b).

  • This prevents exposure to fall hazards while employees are already working and ensures protections are in place at the start of the job.
  • Employers should plan installation of fall protection into the project schedule.

Under 1926.1051(a)(1), does the prohibition on using non-permanent spiral stairways apply if the spiral stairway is brought to the site and anchored temporarily for access?

Yes; employees shall not use any spiral stairways that will not be a permanent part of the structure on which construction work is being performed, so bringing a non-permanent spiral stairway and anchoring it temporarily would not satisfy the rule. See 1926.1051(a)(1).

  • Only spiral stairways that are actually permanent components of the structure are permitted for employee use under this paragraph.
  • Employers should provide other compliant access (stairways, ladders, ramps, personnel hoists) when temporary spiral stairs are the only option.

Under 1926.1051, does the requirement to keep at least one point of access clear (when there are two or more) apply during emergency situations or only during normal operations?

The requirement to keep at least one point of access clear applies generally to permit free passage of employees and is intended to ensure safe movement at all times, including emergencies; see 1926.1051(a)(4).

  • Keeping an access route clear supports safe egress in emergencies as well as routine movement.
  • Employers should plan work so that at least one unobstructed access is maintained at all times.

Under 1926.1051, if only one ladder provides access and work requires more than 25 employees, can the employer rely on temporary work scheduling to keep employee count below 25 instead of providing extra ladders?

The standard sets the requirement threshold at 25 or more employees; if the employer can reasonably ensure fewer than 25 employees will use the ladder at the same time, the double-cleated ladder or two-ladder requirement of 1926.1051(a)(2) may not apply. However, employers must still ensure safe access and egress and plan work to prevent unsafe crowding or simultaneous two-way traffic.

  • Relying on scheduling is acceptable if it effectively prevents the situation that triggers the requirement.
  • Employers should document safe procedures and monitor compliance; if scheduling fails and 25 or more employees must use the ladder, the employer must provide the required ladder configuration.

Under 1926.1051, does the rule require employers to choose stairs over ladders whenever possible?

The rule does not explicitly mandate choosing stairs over ladders, but it requires a stairway or ladder whenever there is a 19-inch (48 cm) or more elevation break and no acceptable alternative (ramp, runway, sloped embankment, or personnel hoist) is provided; employers must select and provide safe means of access. See 1926.1051(a).

  • Employers should choose the safest practical access for the worksite; where feasible, stairways or ramps often provide safer access for higher-traffic areas.
  • Other OSHA standards addressing fall protection and scaffolds may influence the selection of access methods.

Under 1926.1051, does the requirement to provide stairways or ladders apply to residential construction sites the same as to commercial sites?

Yes; the rule in 1926.1051(a) applies to construction work broadly and therefore applies to residential and commercial construction when a 19-inch (48 cm) or greater elevation break exists and no acceptable alternative access is provided.

  • Residential jobsites must meet the same access and egress requirements under the construction standards.
  • Employers should ensure compliance regardless of project type and provide required stairways, ladders, or acceptable alternatives.