3.2 Ladders, Stairways, Scaffolds & Dockboards (1910.23-26)

Portable Ladders (29 CFR 1910.23)

Ladders are ubiquitous tools in general industry, yet improper setup, selection, and use cause thousands of lost-time injuries every year. OSHA standard 29 CFR 1910.23 covers all portable ladders, including non-self-supporting ladders (single and extension ladders) and self-supporting ladders (stepladders).

The 4:1 Slope Rule (75.5 Degree Pitch)

CITATION TRAP: The 2016 Walking-Working Surfaces final rule rewrote Subpart D in performance language, so the numeric 4:1 pitch is no longer spelled out in 1910.23. What 1910.23 does say is that the top of a non-self-supporting ladder must rest with the two rails supported equally unless a single support attachment is fitted (1910.23(c)(12)), and that ladders must be used only on stable and level surfaces unless secured (1910.23(b)(6)). The 4:1 figure itself comes from ANSI A14 and OSHA's construction standard 1926.1053(b)(5)(i), and OSHA guidance still treats it as the accepted way to set a ladder safely in general industry. Know the number, and know it is not a 1910.23 citation.

A non-self-supporting portable ladder should be placed at an angle where the horizontal distance from the top support to the foot of the ladder is approximately one-quarter of the ladder's working length (a 4:1 pitch, roughly 75.5 degrees from horizontal). Working length means the distance along the side rails from the foot of the ladder to the top support point - not the vertical height of the wall.

$\text{Horizontal Base Distance} = \frac{\text{Working Length of Ladder}}{4}$

Example: A ladder set with a working length of 16 feet from foot to top support has its base placed exactly 4 feet out from the wall ($16 \div 4 = 4$). Placing the ladder base too far out creates excessive bending stress and slip hazards at the base, while placing it too close makes the ladder top-heavy and prone to tipping backward.

Landing Extension & Grab Bar Requirement

When a portable ladder is used to access an elevated landing surface (such as a roof, mezzanine, or platform), the ladder side rails must extend at least 3 feet (36 inches) above the upper landing surface (1910.23(c)(11)). This extension provides climbing workers with handholds when stepping onto or off the landing. If extending the ladder 3 feet above the landing is impossible due to overhead restrictions, the ladder must be secured at its top to a rigid structure, and a grab bar or handrail must be installed to assist workers in mounting and dismounting.

Stepladder Safety Rules (1910.23(c)(2))

Self-supporting stepladders (A-frame ladders) must meet strict operational rules:

• Fully Open & Locked: Stepladders must be used only in the fully open position with metal spreader bars or locking braces fully extended and locked in place.
• No Closed Leaning: Using a closed stepladder as a non-self-supporting ladder leaned against a wall or beam is strictly prohibited.
• Top Step Prohibition: Employees are prohibited from standing on the top step or top cap of a stepladder. The top step and cap are not designed as standing platforms.

Ladder Inspection & Tagging Defective Ladders (1910.23(b)(9) & (10))

Ladders must be inspected by a competent person or trained worker prior to initial use on each shift and after any event that could affect their structural integrity (e.g., being struck by a vehicle or dropped). Inspection criteria include checking for cracked rungs, loose rivets, damaged feet/anti-slip shoes, bent side rails, oil/grease accumulation, or broken locking pawls.

When a portable ladder is found to have structural defects or damage:

1. It must be immediately tagged with "Dangerous: Do Not Use" or similar clear warning language.
2. It must be immediately removed from service and sequestered until repaired or destroyed.

+-------------------------------------------------------------+
|                   PORTABLE LADDER SETUP                     |
|                                                             |
|             [Roof / Upper Landing]                          |
|                     ||                                      |
|                     ||  <-- 3 Feet (36 in) Extension        |
|        ==============++==============                       |
|                     /||                                     |
|                    / ||                                     |
|                   /  ||                                     |
|                  /   ||  Working Height = H                 |
|                 /    ||                                     |
|                /     ||                                     |
|               /      ||                                     |
|              /       ||                                     |
|             / 75.5°  ||                                     |
|  [Ground]  /_________||                                     |
|            <---B---->                                       |
|            Base Distance B = H / 4                          |
+-------------------------------------------------------------+

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Fixed Industrial Stairs (29 CFR 1910.25)

RENUMBERING ALERT: Before the 2016 Walking-Working Surfaces rule, fixed stairs lived at 1910.24 and dockboards at 1910.26. Under the current Subpart D the numbering is 1910.23 Ladders, 1910.24 Step bolts and manhole steps, 1910.25 Stairways, 1910.26 Dockboards, 1910.27 Scaffolds and rope descent systems. Citing 1910.24 for a stair violation is a classic open-book exam error - and a fast way to lose points on a question that asks you to name the governing section.

29 CFR 1910.25 establishes specifications for standard stairs, spiral stairs, ship stairs, and alternating tread-type stairs used to access equipment, machinery, tanks, platforms, or adjacent floor levels. Stairways that also serve as part of a means of egress must additionally satisfy Subpart E.

Angle of Inclination & Dimensions

Standard stairs must be installed at an angle of 30 degrees to 50 degrees from the horizontal (1910.25(c)(1)). The standard sets strict dimensional limits on treads and risers:

• Maximum Riser Height: 9.5 inches (24 cm) - 1910.25(c)(2).
• Minimum Tread Depth: 9.5 inches (24 cm) - 1910.25(c)(3).
• Minimum Stair Width: 22 inches (56 cm) between vertical barriers - 1910.25(c)(4).
• Uniformity: Riser heights and tread depths must be uniform between landings - 1910.25(b)(3).
• Vertical Clearance: At least 6 feet 8 inches (203 cm) from any stair tread to any overhead obstruction - 1910.25(b)(2).

Stair Landings & Handrails

Under 1910.25(b)(4), stairway landings and platforms must be at least the width of the stair and at least 30 inches (76 cm) deep, measured in the direction of travel. The often-quoted "landing at every 12 feet of vertical rise" figure came from the pre-2017 1910.24 and from the construction standard 1926.1052 - it is not stated in the current 1910.25, so do not cite it from your 1910 book.

Stair rail and handrail duty comes from Subpart D's fall-protection section, not from 1910.25:

• 1910.28(b)(11)(i): guardrail or stair rail protection is required at any stairway landing or platform edge 4 feet or more above a lower level.
• 1910.28(b)(11)(ii): each flight of stairs having at least 3 treads and at least 4 risers must be equipped with stair rail systems and handrails.
• 1910.29(f): gives the construction criteria for stair rail systems and handrails (handrail height 30 to 38 inches; stair rail top edge at least 42 inches for systems installed on or after January 17, 2017).

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Step Bolts & Manhole Steps (29 CFR 1910.24)

29 CFR 1910.24 is the section most often mis-cited on the exam. It has nothing to do with stairs. It covers step bolts - individual rungs bolted into poles, towers, tanks, and vessel walls - and manhole steps used to climb into utility vaults and sewers.

Both devices must be inspected at the start of the work shift and maintained; any bent, cracked, corroded, or loose step bolt or manhole step must be corrected or repaired before an employee uses it.

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Dockboards & Loading Ramps (29 CFR 1910.26)

Loading docks present severe fall and crush hazards due to vehicle movement, heavy forklift loads, and open drop-offs. 29 CFR 1910.26 governs portable and powered dockboards (bridge plates) used to bridge the gap between loading platforms and transport vehicles (truck trailers or railcars).

Core Engineering & Operational Controls:

1. Load Capacity: Dockboards must be strong enough to carry the maximum intended load imposed by forklifts, pallet jacks, and freight.
2. Anchoring & Securing: Portable dockboards must be secured in position, either by being anchored with pins or equipped with positive locking devices/cleats to prevent accidental sliding or displacement during freight loading.
3. Safe Handling: Portable dockboards must feature handholds, handles, or fork loops to allow safe manual or mechanical positioning without pinching hands.
4. Run-Off Guards: Portable dockboards must be equipped with side curbs or run-off guards to prevent forklift wheels from running off the lateral edges.
5. Fall Protection on Dock Edges: Under 1910.28(b)(1)(i), open loading dock edges or dockboards where an employee is exposed to a fall hazard of 4 feet or more to a lower level must be protected by guardrails, removable railing systems, or alternative fall protection when transport vehicles are not docked.

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Scaffolds in General Industry (29 CFR 1910.27)

Under 29 CFR 1910.27, OSHA mandates that all scaffolds used in general industry facilities (e.g., during maintenance, painting, equipment overhauls, or building repairs) must meet the design, construction, loading, and fall protection requirements of 29 CFR 1926 Subpart L (Scaffolds in Construction).

Key scaffold rules incorporated into general industry include:

• 4x Safety Factor: Scaffolds and scaffold components must be capable of supporting, without failure, their own weight and at least 4 times the maximum intended load.
• Planking Requirements: Scaffold platforms must be fully planked or decked with solid scaffold-grade lumber or metal decks, with no gaps greater than 1 inch.
• Fall Protection Trigger: On scaffolds, fall protection (guardrails or personal fall arrest systems) is required at a height of 10 feet above a lower level (per 1926 Subpart L rules referenced by 1910.27).

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Technical Specifications Summary Matrix