OSHA recently issued a standard letter of interpretation on using a stepladder as a non-self-supporting ladder.
In the letter, Richard Fairfax, acting director of the agency’s Directorate of Construction, said using a stepladder as a non-self-supporting ladder would violate 1926.1053(b)(4) unless the ladder was designed for that purpose. He added that because stepladders usually are designed so the rungs are level when the ladder is open and locked on a stable surface, it is likely that positioning a stepladder for use as a non-self-supporting ladder would make the rungs unlevel — also a violation of the standard.
