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OSHA 1926.851

Stairs and access in demolition

Subpart T

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.851(a), which stairways, passageways, and ladders are allowed for access during demolition?

Only the stairways, passageways, and ladders that have been designated as means of access to the structure may be used; all other access ways must be entirely closed at all times. See 1926.851(a).

  • Make sure the site plan or supervisor clearly identifies which routes are "designated" as access.
  • Physically block and sign non-designated routes so workers cannot use them.

Under 1926.851(a), do non-designated or ad-hoc access ways have to be kept open for convenience during demolition?

No — non-designated access ways must be entirely closed at all times; they are not to be used for convenience. See 1926.851(a).

  • Closing non-designated routes prevents accidental entry into unsafe areas and limits exposure to falling debris or unstable structure.

Under 1926.851(b), how often must stairs, passageways, and ladders be inspected and maintained during demolition?

They must be periodically inspected and maintained in a clean, safe condition. See 1926.851(b).

  • "Periodically" is not defined in the standard; employers should set inspection frequency based on site hazards and conditions (for example, before each shift or after weather events) to ensure continued safety.
  • Inspections should check for loose treads, obstructed passageways, lighting, handrail condition, and debris accumulation.

Under 1926.851(b), what does "maintained in a clean safe condition" mean for stairways and passageways on a demolition site?

It means the stairways, passageways, ladders and related equipment must be kept free of hazards (like debris, loose material, and slippery substances) and kept in a condition that does not create a hazard for workers. See 1926.851(b).

  • Practical examples: remove tripping debris, clear snow/ice, repair broken treads, secure loose handrails, and ensure lighting works.
  • If hazardous materials (e.g., asbestos) may be present, follow the applicable hazardous-material standards in addition to keeping accessways clean; see OSHA's asbestos interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 when asbestos remediation is involved.

Under 1926.851(c), what lighting and covering requirements apply when a stairwell in a multistory building is used during demolition?

When a stairwell in a multistory building is being used, it must be properly illuminated (by natural or artificial light) and it must be completely and substantially covered at a point not less than two floors below the floor where work is being performed; access to the work floor must then be through a properly lighted, protected, and separate passageway. See 1926.851(c).

  • For example: if work is on the 5th floor, the stairwell must be covered at or below the 3rd floor.
  • "Properly illuminated" allows either daylight or temporary artificial lighting, but the lighting must be sufficient for safe travel.

Under 1926.851(c), what does "completely and substantially covered over at a point not less than two floors below" mean in practice?

It means you must install a solid, substantial cover across the stairwell at least two full floors below the floor where demolition work is occurring so the open stair shaft is not exposed to falling materials or people. See 1926.851(c).

  • The cover must be strong enough to stop debris and protect anyone below; it should be continuous (no gaps) at the specified level.
  • Example: work on 6th floor → cover stairwell at 4th floor or lower.
  • If falling-object hazards exist, also apply falling-object protection practices such as those discussed for suspended scaffolds in OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.

Under 1926.851(c), can temporary artificial lights be used to meet the illumination requirement for stairwells at night?

Yes — stairwells may be properly illuminated by artificial lighting if natural light is not available, so temporary lights are acceptable as long as illumination is adequate for safe travel. See 1926.851(c).

  • Ensure temporary lighting is installed and maintained so it does not create trip or electrical hazards (cords routed safely, fixtures secure).

Under 1926.851(c), must access to the floor where demolition work is performed go through the stairwell being used for general building access?

No — access to the floor where work is in progress must be through a properly lighted, protected, and separate passageway, not through the stairwell being used for general building access unless that stairwell meets the separate protected-passageway criteria. See 1926.851(c).

  • The intent is to separate the route workers use to reach the work area from general circulation to reduce exposure to falling debris, hazards, and disruption.

Under 1926.851(b), does the standard require written records of the periodic inspections of stairs and passageways?

No — 1926.851(b) requires that stairs, passageways, ladders and incidental equipment be periodically inspected and maintained in a clean safe condition, but it does not require written records of those inspections. See 1926.851(b).

  • Although not required by this paragraph, documenting inspections is a best practice and helps show due diligence if questions arise during an inspection or incident investigation.

Under 1926.851, can a temporary stairwell be designated as a means of access during demolition?

Yes — a temporary stairway may be used if it is formally designated as a means of access and is kept in the required safe, clean condition and inspected periodically. See 1926.851(a) and 1926.851(b).

  • Before using a temporary stair, ensure it is installed to be safe and that all non-designated access routes are closed.

Under 1926.851(c), how should passageways be protected from falling objects during demolition?

Passageways used for access to work floors must be protected so they are safe from falling objects; this is accomplished by providing a separate, protected passageway and by covering stairwells as required. See 1926.851(c).

  • For additional guidance on falling-object protection in related suspended-work settings, see OSHA's interpretation on fall and falling-object protections at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.
  • Use canopies, toe-boards, debris nets, or covered walkways where appropriate to keep workers and the public safe.

Under 1926.851, who should ensure that non-designated access ways are closed and designated access is maintained?

The employer/site management is responsible for ensuring that only designated means of access are used and that other access ways are entirely closed and that designated access is inspected and maintained. See 1926.851(a) and 1926.851(b).

  • Supervisors should document how access routes are designated, closed, and inspected as part of their site safety procedures.

Under 1926.851, does the multistory stairwell covering requirement apply if the stairwell is not being used?

No — the specific multistory stairwell illumination and covering requirements in 1926.851(c) apply when a stairwell is being used; if the stairwell is not used, the employer must still prevent unsafe access and keep any used accessways safe as required by 1926.851(a) and (b). See 1926.851(c) and 1926.851(a).

  • Even unused stairwells on demolition sites should be secured to prevent inadvertent entry.

Under 1926.851(b), do inspections of stairs and passageways include incidental equipment such as handrails and lighting fixtures?

Yes — 1926.851(b) covers stairs, passageways, ladders and incidental equipment thereto, so inspections should include handrails, lighting fixtures, guards, and other related equipment to ensure they are in a clean, safe condition. See 1926.851(b).

  • Check handrail fasteners, switches and fixtures for secure installation and function during inspections.

Under 1926.851(c), if natural light reaches the stairwell during the day, does the standard still require artificial lighting?

No — artificial lighting is not required if natural lighting provides proper illumination; the stairwell must simply be properly illuminated by natural or artificial means. See 1926.851(c).

  • If natural light is insufficient at certain times (e.g., dusk, overcast days), provide artificial lighting so conditions remain safe.

Under 1926.851, how should employers handle stairway access during asbestos remediation on a demolition site?

Employers must still use only designated accessways and keep them clean and safe per 1926.851, and when remediation involves asbestos-containing materials the asbestos construction standard applies to the work and controls (including respiratory protection and work practices) must be followed. See 1926.851(b) and OSHA's asbestos interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14.

  • In practice: keep accessways free of asbestos-contaminated debris, restrict access, and ensure workers follow 29 CFR 1926.1101 procedures for Class I–IV asbestos work as applicable (see the asbestos interpretation for scope guidance).

Under 1926.851(c), can a single passageway be used both for workers going to the work area and for moving debris from higher floors?

No — access to the floor where work is in progress must be through a properly lighted, protected, and separate passageway; mixing worker access and debris movement increases hazard and is inconsistent with the requirement for a protected separate passageway. See 1926.851(c).

  • Use separate chutes, hoists, or protected routes to move debris so the access passageway remains safe for foot traffic.

Under 1926.851, does the standard apply differently to single-story versus multistory demolitions?

Yes — the general requirements in 1926.851(a) and (b) (use only designated access and periodic inspection/maintenance) apply to all demolition, while the specific stairwell illumination and two-floor covering requirement in 1926.851(c) applies only to multistory buildings when a stairwell is being used. See 1926.851(a), 1926.851(b), and 1926.851(c).

  • For single-story sites, focus on keeping designated accessways safe and closed off non-designated routes.

Under 1926.851(b), should inspection frequency be changed after severe weather or heavy demolition activity?

Yes — because 1926.851(b) requires periodic inspections and maintenance to keep accessways safe, you should increase inspection frequency after severe weather or heavy demolition that could create new hazards; the standard requires periodic inspections but does not prescribe fixed intervals. See 1926.851(b).

  • Best practice: inspect before each shift and after events that can degrade condition (storms, heavy loads, impacts).

Under 1926.851(c), if workers need to pass through a stairwell below the covered level, can the cover be partial or must it be continuous?

The stairwell must be "completely and substantially covered" at the specified point (not less than two floors below the work floor), so the cover must be continuous and substantial at that level — partial or gap-filled covers would not meet the requirement. See 1926.851(c).

  • Ensure covers are structurally sound and free of gaps; they must block falling materials and prevent accidental falls into the stair shaft.