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OSHA 1926SubpartXAppA

Ladder strength guidelines

Subpart X

18 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1053(a)(1), does OSHA require employers to follow Appendix A to Subpart X (Ladders)?

No — Appendix A to Subpart X is a non‑mandatory guideline and not a required regulation. Appendix A states it "serves as a non-mandatory guideline to assist employers in complying with the ladder loading and strength requirements of 1926.1053(a)(1)," so employers may use it as guidance but are still required to meet the mandatory requirements in 1926.1053(a)(1).

Under 1926.1053(a)(1), will OSHA consider a ladder built to an ANSI standard as meeting the ladder strength requirement?

Yes — a ladder designed and built in accordance with the applicable national consensus ANSI standards listed in Appendix A will be considered to meet the ladder loading and strength requirements of 1926.1053(a)(1). Appendix A explicitly lists the ANSI standards recognized by OSHA for different ladder types.

Under 1926.1053(a)(1), which ANSI standard does Appendix A identify for manufactured portable wood ladders?

Appendix A identifies ANSI A14.1-1982 as the relevant standard for manufactured portable wood ladders. The appendix lists specific consensus standards, stating that "Manufactured portable wood ladders: American National Standards Institute (ANSI) A14.1-1982" will be considered to meet the requirements of 1926.1053(a)(1).

Under 1926.1053(a)(1), which ANSI standard covers manufactured portable metal ladders according to Appendix A?

Appendix A identifies ANSI A14.2-1982 as the applicable standard for manufactured portable metal ladders. The appendix lists "Manufactured portable metal ladders: ANSI A14.2-1982" as a consensus standard that OSHA will consider to satisfy 1926.1053(a)(1).

Under 1926.1053(a)(1), what ANSI standard does Appendix A list for manufactured fixed ladders?

Appendix A lists ANSI A14.3-1984 for manufactured fixed ladders. OSHA's appendix states that "Manufactured fixed ladders: ANSI A14.3-1984" will be considered to meet the ladder strength and loading requirements of 1926.1053(a)(1).

Under 1926.1053(a)(1), which ANSI standard should be used for job-made ladders according to Appendix A?

Appendix A identifies ANSI A14.4-1979 as the standard for job-made ladders. The appendix specifically lists "Job-made ladders: ANSI A14.4-1979" as a consensus standard OSHA will consider to meet the requirements of 1926.1053(a)(1).

Under 1926.1053(a)(1), what guidance does Appendix A give for plastic (reinforced plastic) ladders?

Appendix A names ANSI A14.5-1982 as the applicable standard for portable reinforced plastic ladders. The appendix lists "Plastic ladders: ANSI A14.5-1982" as one of the consensus standards that will be considered by OSHA to meet the 1926.1053(a)(1) ladder strength requirements.

Under 1926.1053(a)(1), if a ladder meets a newer ANSI version than the year listed in Appendix A, does Appendix A say it is acceptable?

Appendix A itself lists specific ANSI editions and says ladders designed and built "in accordance with the applicable national consensus standards, as set forth below, will be considered to meet the requirements of 1926.1053(a)(1)." It does not explicitly address newer ANSI revisions, so an employer who relies on a newer consensus standard should document how that standard provides equivalent or better strength and loading protection and ensure the ladder meets 1926.1053(a)(1).

Under 1926.1053(a)(1), does using an ANSI‑compliant ladder relieve an employer of all duties under the OSHA ladder standard?

No — using an ANSI‑compliant ladder does not relieve the employer of responsibilities under OSHA. Appendix A says ANSI‑conforming ladders "will be considered to meet" the loading and strength requirements of 1926.1053(a)(1), but employers must still ensure ladders are safe for the specific work, maintained, inspected, and used according to OSHA requirements in 1926.1053.

Under 1926.1053(a)(1), can an employer use other national consensus ladder standards not listed in Appendix A to show compliance?

Yes — Appendix A lists several ANSI standards that OSHA will consider, but it does not say these are the only acceptable consensus standards. A ladder designed and built in accordance with other appropriate national consensus standards may also demonstrate compliance with 1926.1053(a)(1) provided the employer can show the ladder meets the required loading and strength objectives.

Under 1926.1053(a)(1), where can employers find the OSHA ladder loading and strength requirement text?

Employers can find the mandatory ladder strength and loading requirement in 1926.1053(a)(1). Appendix A to Subpart X provides non‑mandatory guidance and lists consensus standards that OSHA will consider to satisfy that requirement.

Under 1926.1053(a)(1), does Appendix A change the legal force of the OSHA ladder standard?

No — Appendix A is advisory and does not change the mandatory OSHA regulation. The appendix is explicitly a "non-mandatory guideline" to assist employers in meeting the statutory requirement in 1926.1053(a)(1); the enforceable duties remain those stated in the OSHA standard itself.

Under 1926.1053(a)(1), if a ladder is job‑made, which consensus standard does Appendix A recommend and what should the employer do?

Appendix A recommends designing job‑made ladders to meet ANSI A14.4-1979. Employers who build job‑made ladders should follow that consensus guidance or equivalent methods to meet the loading and strength requirements of 1926.1053(a)(1) and keep documentation showing the ladder design meets those requirements.

Under 1926.1053(a)(1), who is responsible for ensuring a ladder meets the strength and loading requirements?

The employer is responsible for ensuring ladders meet the strength and loading requirements of 1926.1053(a)(1). Appendix A provides non‑mandatory consensus standards (for example, ANSI A14.1‑1982 for wood ladders) that employers can use to demonstrate compliance, but the ultimate duty to provide safe equipment rests with the employer under the OSHA standard.

Under 1926.1053(a)(1), does Appendix A list standards for fixed ladders attached to buildings?

Yes — Appendix A lists ANSI A14.3-1984 for manufactured fixed ladders, which covers fixed ladders attached to structures. Appendix A says a ladder built to that consensus standard "will be considered to meet the requirements of 1926.1053(a)(1)," so employers using such fixed ladders should ensure they meet 1926.1053(a)(1).

Under 1926.1053(a)(1), are plastic reinforced ladders addressed by Appendix A and which standard applies?

Yes — Appendix A addresses portable reinforced plastic ladders and identifies ANSI A14.5-1982 as the consensus standard for those ladders. Appendix A says ladders built to that standard "will be considered to meet" the ladder strength requirements of 1926.1053(a)(1).

Under 1926.1053(a)(1), if a ladder manufacturer provides a certificate of design to ANSI A14.2-1982, does Appendix A indicate this helps show compliance?

Yes — Appendix A indicates that ladders designed and built in accordance with the listed ANSI standards (for a manufactured portable metal ladder, ANSI A14.2-1982) "will be considered to meet" 1926.1053(a)(1). A manufacturer's certificate showing conformance to the listed standard is useful documentation for demonstrating compliance to OSHA.

Under 1926.1053(a)(1), does Appendix A provide design load values or test procedures employers must use?

No — Appendix A does not itself provide specific design load values or test procedures; it identifies consensus ANSI standards that contain such technical specifications. Employers who need the detailed load and test criteria should consult the listed standards (for example, ANSI A14.1‑1982 for wood ladders) and ensure the ladder meets 1926.1053(a)(1).