1910.23(c)(8): Do Not Stand on Stepladder Top
Employers must make sure the cap (if the ladder has one) and the top step of a stepladder are not used as steps.
Key takeaways
- 1910.23(c)(8) is part of OSHA's general industry standards (29 CFR Part 1910, Subpart D).
- OSHA cited it 61 times in the last 3 years, in 61 inspections, with $227,445 in current penalties.
- 1 death is linked to inspections that cited this rule.
- Most citations: OR (8), OH (4), MA (4).
- Related part: 1910.23(c) Portable ladders (462 citations).
- Free 5-minute toolbox talk for your crew below.
In this article
What this rule covers
29 CFR 1910.23(c)(8) is one requirement inside 1910.23 Ladders, an OSHA general industry standard (Part 1910, Subpart D). The official text below is copied word for word from the Electronic Code of Federal Regulations (eCFR). The numbers, injury cases and training on this page show how OSHA enforces it on real job sites.
Official text
(8) The cap (if equipped) and top step of a stepladder are not used as steps; 61 citations
Source: eCFR, text current as of 2026-10-15. Read all of 1910.23.
Injuries linked to this rule
1 death is linked to inspections where OSHA cited 1910.23(c)(8).
At 10:40 a.m. on December 4, 2024, Employee #1 was in the attic of a building changing filters on two air conditioning units. During the task, the employee fell through an attic access point and landed on the ground. The employee was found unconscious with…
Where and how often it was cited
| Year | Citations |
|---|---|
| 2023 | 3 |
| 2024 | 17 |
| 2025 | 27 |
| 2026 | 14 |
Top states: OR (8), OH (4), MA (4), MI (4), HI (3)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| VTCU, CORP. | POCATELLO, ID | $16,550 |
| DICK'S SPORTING GOODS, INC. | SCHAUMBURG, IL | $16,550 |
| UNIQLO DISNEY SPRINGS | LAKE BUENA VISTA, FL | $16,550 |
| MAR-JAC POULTRY MS, LLC | HATTIESBURG, MS | $14,062 |
| TAKE 5 OIL CHANGE, LLC | FORT WORTH, TX | $11,524 |
Free toolbox talk
A 5-minute crew talk on 1910.23(c)(8), plus alerts when this rule changes. Free.
OSHA interpretation letters
None exist. OSHA has not published a letter of interpretation for 1910.23(c)(8).
Related parts of this rule
- 1910.23(c) Portable ladders 462 citations
- 1910.23(c)(11) 198 citations
- 1910.23(c)(3) 68 citations
- 1910.23(c)(7) 42 citations
- 1910.23(c)(4) 38 citations
- 1910.23(c)(9) 33 citations
- 1910.23(c)(7)(i) 21 citations
- 1910.23(c)(2) 7 citations
- 1910.23(c)(7)(ii) 6 citations
- 1910.23(c)(1) 3 citations
Get your crew competent
Trainers on Black Belt Safety: Marc Harvey, Dana Reyes
Trainers and suppliers: feature your business on this rule for $25/month.
Frequently asked questions
Can I stand on the top step of a stepladder?
No. The top step of a stepladder is not to be used as a step.
What about the cap?
If the stepladder has a cap, it is not to be used as a step either.
What should I do if I cannot reach?
Use a taller ladder or other suitable equipment instead of the cap or top step.
About this page
Sources
- 29 CFR 1910.23 (eCFR), text current as of 2026-10-15
- U.S. Department of Labor enforcement data: OSHA inspections, citations and accident records, copied nightly; data as of 2026-10-20
3-year window. Federal OSHA only; state-plan rules are not counted. Plain-language text is a summary, not legal advice; the official text controls. Black Belt Safety is not part of OSHA or the Department of Labor.