Worker on an unopened stepladder that’s leaning against a wall—is that okay if another worker holds the ladder to prevent it from slipping?  What does OSHA say?  Violation or not?

According to a 1/21/10, OSHA letter of interpretation, the short answer is “no”.

Why? (Or the long answer.)

29CFR1926 Subpart X, 1926.1053(b)(4) states:  Ladders shall be used only for which they were designed.

Thus, using a stepladder as a non-self-supporting ladder would violate §1926.1053(b)(4) if the ladder were not designed for that purpose.  Stepladder design varies from manufacturer to manufacturer.   To further the fact that ladders can’t be used as straight ladders, American National Standards Institute (ANSI) standards state that “self-supporting ladders shall not be used as single ladders or in the partially closed section”.

OSHA also quotes 1926.1053(a)(2):  Ladder rungs, cleats, and steps shall be…level…when the ladder is in position for use.

Stepladders are typically designed so that the rungs are level when the ladder is in the open and locked position and the ladder is placed on a stable and level surface. Consequently, it is likely that positioning a stepladder for use as a non-self-supporting ladder would result in the ladder's rungs being out-of-level, which would violate 1926.1053(a)(2).

The long and short of it is only work from stepladders that are opened fully and locked.