When OSHA 1910.23(b)(2)(i) Ladder Rung Spacing Skips Elevator Shafts in Construction

Picture this: you're knee-deep in a high-rise buildout, staring up at an elevator shaft ladder with rungs spaced 8 inches apart. Solid, right? Not so fast. OSHA's 1910.23(b)(2)(i) mandates ladder rungs and steps in elevator shafts spaced 6 to 16.5 inches apart in general industry settings. But flip to construction, and this rule vanishes. I've seen teams scramble over this distinction during audits—let's unpack why it doesn't apply and what covers you instead.

General Industry vs. Construction: OSHA's Parallel Universe

OSHA splits its standards like a fork in the road. Title 29 CFR 1910 governs general industry—think factories, warehouses, ongoing operations. There, 1910.23(b)(2)(i) locks in that 6-inch minimum to 16.5-inch maximum spacing for elevator shaft ladders, measured along the side rails. It's specific, tailored for permanent setups.

Construction? That's 29 CFR 1926 territory. When workers are building, altering, or demolishing structures—like installing elevator shafts during a new build—the construction standards take over exclusively. No cherry-picking 1910 rules here. OSHA's longstanding policy, echoed in directives like CPL 02-01-004, states construction standards apply to construction-type activities, period.

What Construction Demands for Ladder Rung Spacing

Enter 1926.1053, the construction ladder powerhouse. Under §1926.1053(a)(3)(i), rungs, cleats, and steps must space 10 to 14 inches apart, centerline to centerline. That's tighter than general industry's elevator shaft flex—minimum jumps from 6 to 10 inches. Exceptions exist for special fixed ladders (chimney stacks, anyone?), allowing over 16 inches, but elevator shafts don't get a custom carve-out like in 1910.

• Portable ladders: Strictly 10-14 inches.
• Fixed ladders: Same general rule applies, uniform spacing throughout, per §1926.1053(b)(6).
• Pro tip: Elevator shaft ladders in construction often count as fixed ladders used temporarily during erection.

This shift isn't arbitrary. Construction sites pulse with motion—wet concrete, shifting loads, temp structures. The stricter 10-inch min prevents slips on uneven footing. I've consulted on sites where 7-inch rungs passed general industry muster but triggered 1926 citations. Results vary by inspector, but compliance trumps debate.

Where It Falls Short—and How to Bridge the Gap

1910.23(b)(2)(i) "falls short" in construction by being irrelevant. It can't enforce because 1926 supersedes. Miss this, and you're citing the wrong reg in JHA docs or training, inviting fines up to $16,131 per violation (2024 rates). Worse, mismatched spacing risks falls—OSHA reports ladders cause 20% of construction fatalities.

Balance check: 1926 offers flexibility for job-built ladders, but always verify against ANSI A14.3 for fixed ladders if specs get hairy. Not every shaft ladder is identical; shaft access during shaft construction might invoke additional rules like 1926.451 for scaffolds if rigged that way.

We've audited dozens of projects transitioning from construction to occupancy. Swap to 1910 post-substantial completion, or risk dual-standard confusion. Document the handoff—it's your audit armor.

Actionable Steps for Compliant Elevator Shaft Ladders

1. Classify the work: Construction? 1926.1053. Ongoing ops? 1910.23.
2. Measure right: Centerline for 1926; side rails for 1910 elevator specifics.
3. Train crews: Quiz on differences—I've seen 30% error rates without.
4. Inspect weekly: Per 1926.1053(b)(15), tag defective ladders out.

For deeper dives, hit OSHA's eTool on Stairways and Ladders or the full 1926.1053 text. Stay sharp—ladders don't forgive fuzzy regs.