Stairways and ladders requirements

Yes — podium ladders that include an elevated platform for employees meet the OSHA definition of a scaffold, so the scaffold rules in Subpart L apply rather than Subpart X. See the OSHA letter explaining that the pictured podium ladder has both an elevated platform and access ladder and therefore "meets the definition of a scaffold" (Podium ladder OSHA coverage | 2007-12-10) and consult 29 CFR 1926 Subpart X for ladder/stairway provisions when devices are not scaffolds.

Yes — if the podium ladder is on casters it is treated as a mobile scaffold and must meet mobile scaffold requirements in addition to the general scaffold rules. The OSHA letter on podium ladders notes that devices shown on casters are subject to mobile scaffold rules, so you must comply with those requirements (Podium ladder OSHA coverage | 2007-12-10) and consult 29 CFR 1926 Subpart X and the scaffold provisions for applicable details.

Yes — scaffold stairs that meet the requirements of 29 CFR 1926 Subpart X may be used for temporary access to upper floors during construction. OSHA's letter states that "scaffold stairs which meet all the requirements of Subpart X may be used for temporary access to upper floors" (Scaffold stairs for floor access | 1999-02-01) and you should follow the stairway requirements in 29 CFR 1926 Subpart X.

The federal minimum clear width for stairways under 29 CFR 1926 Subpart X is 22 inches, but some states may require wider widths. OSHA's letter notes that the federal requirement in 1926.1052(a)(1) is 22 inches while California has a more stringent 24-inch requirement (Scaffold stairs for floor access | 1999-02-01). Always check 29 CFR 1926 Subpart X and your State plan for any stricter state rules.

Yes — scaffold stairs used as temporary stairways must meet Subpart X requirements for landings and handrails (including 30-inch landing depths where required) if they are to be used as stairways rather than as scaffold access only. OSHA's guidance on scaffold stairs used as temporary access confirms that scaffold stairs must meet the Subpart X features such as treads, handrails, and 30-inch landings to be acceptable for temporary stairway use (Scaffold stairs for floor access | 1999-02-01); see 29 CFR 1926 Subpart X for the specific requirements.

Yes — OSHA does not categorically prohibit those ladder attachments, but any ladder with attachments must still comply with all Subpart X requirements and the ladder's rated capacity. The OSHA interpretation explains that cable hook assemblies, pole grip assemblies, and adjustable levelers are not expressly prohibited, but employers must meet applicable provisions such as 1926.1053(b)(1), (3), (6), (7), (9), and (10) and ensure attachments do not cause the ladder to be used beyond its intended capacity (Ladder attachment permissibility | 2009-03-16-3). See 29 CFR 1926 Subpart X for the ladder rules.

An extension ladder used for access must extend at least 3 feet above the upper landing surface, or if that extension is not possible due to ladder length it must be secured at the top and a grasping device provided. OSHA's interpretation reiterates the 3-foot extension rule and the alternative of securing the ladder top to a rigid support and providing a grabrail when extension isn't possible (Ladder attachment permissibility | 2009-03-16-3); consult 29 CFR 1926 Subpart X for the full text.

Sometimes — an adjustable leveler may in some situations be equivalent to placing a ladder on a level surface, but OSHA warns its effectiveness depends on many factors and does not guarantee it will always eliminate the need to secure the ladder. The interpretation states that an adjustable leveler may be equivalent to a level surface in some instances but effectiveness depends on surface type, degree of unevenness, and the device's capability (Ladder attachment permissibility | 2009-03-16-3); follow 29 CFR 1926 Subpart X and secure the ladder whenever it is not on a stable, level surface.

No — using attachments that cause the ladder to be loaded beyond its intended or manufacturer's rated capacity is not allowed. OSHA's interpretation explicitly states ladders "shall not be loaded beyond the maximum intended load" and that attachments which impose loads that exceed the ladder's capacity would be prohibited (Ladder attachment permissibility | 2009-03-16-3); see 29 CFR 1926 Subpart X for the related ladder-loading provisions.

You must secure the ladder or provide slip-resistant feet; simply relying on slip-resistant feet alone is not a substitute for proper placement, lashing, or holding when the surface can become slippery. OSHA's interpretation says ladders "shall not be used on slippery surfaces unless secured or provided with slip-resistant feet" and warns that slip-resistant feet should not replace care in placing or securing the ladder (Ladder attachment permissibility | 2009-03-16-3); consult 29 CFR 1926 Subpart X for the detailed requirements.

Scaffold access way stairs are stair systems built into scaffold structures for scaffold platform access and may not meet Subpart X stair dimensions; when scaffold stairs are used to access locations other than scaffold platforms they must meet Subpart X stairway requirements. OSHA's letter explains that when scaffold stairs are used for access to places other than scaffold platforms, the provisions of Subpart X apply, and notes that many tower scaffold stairs do not meet Subpart X requirements (width, handrails, treads, 30-inch landings) (Scaffold stairs for floor access | 1999-02-01); see 29 CFR 1926 Subpart X for the stairway rules.

Yes — a device that combines an elevated platform for employees with an access ladder meets OSHA's scaffold definition and is regulated under Subpart L (scaffolds), not Subpart X. The podium ladder letter states that such a device "incorporates both an elevated platform for supporting employees and an access ladder to the platform" and therefore must meet Subpart L requirements (Podium ladder OSHA coverage | 2007-12-10); consult 29 CFR 1926 Subpart X for ladder/stair provisions where applicable.

If the scaffold or podium ladder is on casters, you must comply with the mobile scaffold requirements in addition to general scaffold rules; OSHA's podium ladder letter specifically calls out that caster-mounted devices are subject to mobile scaffold provisions in 1926.452(w) (Podium ladder OSHA coverage | 2007-12-10). Review 29 CFR 1926 Subpart X and the scaffold rules for safe use, erection, and movement of mobile scaffolds.

The top of a non-self-supporting ladder must have its two rails supported equally unless the ladder is equipped with a single support attachment. OSHA lists 1926.1053(b)(10) among the requirements employers must follow when using ladders with attachments (Ladder attachment permissibility | 2009-03-16-3); see 29 CFR 1926 Subpart X for the exact provision.

No — tower scaffold stairs that do not meet Subpart X dimensional and handrail requirements generally should not be used as temporary stairways to access floors. OSHA's letter points out that tower scaffold stairs often do not meet the Subpart X criteria (minimum width, handrails, treads, 30-inch landings) and therefore would not be acceptable as temporary stairways under federal rules (Scaffold stairs for floor access | 1999-02-01); see 29 CFR 1926 Subpart X for the stairway standards.

An employer should ensure the attachment does not overload or destabilize the ladder, that the ladder remains secured on stable supports, and that the ladder's rated capacity is not exceeded. OSHA's interpretation allows such attachments but emphasizes compliance with Subpart X requirements (including load limits and secure placement) and cautions that attachments must not create loads beyond the ladder's intended capacity (Ladder attachment permissibility | 2009-03-16-3); consult 29 CFR 1926 Subpart X for the ladder rules.

Yes — employers must keep the area around the top and bottom of ladders clear to prevent displacement and other hazards. OSHA lists 1926.1053(b)(9) among the pertinent ladder requirements and includes it in the guidance on ladder attachments and safe ladder use (Ladder attachment permissibility | 2009-03-16-3); see 29 CFR 1926 Subpart X for the full requirement.

Employers must follow the stricter state requirement when the State administers its own OSHA plan; a State plan may be more protective than federal OSHA. OSHA's letter referenced California's 24-inch stair width requirement as more stringent than the federal 22-inch requirement and emphasized that State-plan employers must comply with their State's rules (Scaffold stairs for floor access | 1999-02-01); consult 29 CFR 1926 Subpart X and your State plan for specifics.

A temporary stair on scaffolding is compliant when it meets Subpart X design requirements such as minimum width, proper treads, handrails, appropriate slope, and required landings; scaffold stairs used as access to other floors must meet these features. OSHA's guidance states scaffold stairs which meet all Subpart X requirements may be used for temporary access, while many scaffold-specific stairs do not meet those criteria and therefore are not acceptable as temporary stairways (Scaffold stairs for floor access | 1999-02-01); see 29 CFR 1926 Subpart X for the details.