Compliance Statement

Effective January 17, 2017, OSHA 1910 Subpart D (§1910.23 (e) (2) (i)) permits employers to use mobile ladder stands (rolling ladders) with a climb angle of 60 degrees or less, with no minimum climb angle. This is consistent with the requirements of the applicable consensus standard for rolling ladders, ANSI ASC A14.7-2011, Safety Requirements for Mobile Ladder Stands and Mobile Ladder Stand Platforms (“ANSI A14.7”), paragraph 4.3.3.

However, the revised OSHA regulations (§1910.23 (b) (11)) require that employers ensure that climbers of all ladders face the ladder steps when climbing up or down.  ANSI A14.7, paragraph 6.10, permits climbers to descend a rolling ladder facing forward (away from the ladder) if the climb angle is 50 degrees or less.

Therefore, effective January 17, 2017, 50 degree or lesser climb angle ladders comply with the design requirements of applicable OSHA regulations and ANSI standards. However, for these ladders effective January 17, 2017, forward facing descent (climbing down while facing away from the ladder steps) is a use that is not permitted by OSHA 1910 subpart D, but is permitted by ANSI A14.7.

Revisions of OSHA 1910 Subpart D – Walking-Working Surfaces (click here) and ANSI ASC A14.7-2011 American National Standard for Mobile Ladder Stands and Mobile Ladder Stand Platforms (click here) or more specifically (click here).

Revisions of OSHA 1910 Subpart D – Walking-Working Surfaces (click here), and ANSI A1264.1 Safety Requirements for Workplace Walking/Working Surfaces… (click here), change the requirements for guardrail systems, including gates.  Compliance with these revisions requires changes to the installation of  Cotterman Adjustable Self-Closing Safety Gates.

The revisions to OSHA 1910 Subpart D are effective January 17, 2017  and ANSI A1264.1-2017 which  has an ANSI Standards Action Publication date of January 20, 2017, is expected to be available for purchase in February 2017.

We strongly advise immediate compliance with the new OSHA and ANSI requirements. Accordingly, we have issued revised instructions available at

We strongly advise that all employers or other responsible parties immediately ensure that all installations of Cotterman Adjustable Self-Closing Safety Gates comply with the revised instructions and that their guardrail systems comply with all requirements of the revised OSHA 1910 Subpart D and, when published, the requirements of ANS1264.1-2017.