Raising concerns about fixed stairways in delivery work areas

Raise a concern about fixed stairways in delivery work areas by identifying the exact flight, describing the condition you observed, and asking your supervisor or designated safety contact to arrange an assessment. If you are concerned about using the stairs for your next task, request instructions for a safe way between the levels before proceeding.

Explain which levels the stairs connect, what you were doing, and whether the concern involves a particular step, the landing, overhead space or a rail. You can report what you observed without first deciding whether it violates a standard. A precise location also helps the person receiving the report assign the assessment to someone who can inspect that flight.

Understand what the stairway source covers

OSHA's 1910.25 stairways standard provides the federal general-industry baseline discussed here. Paragraph (a) covers several stair types and excludes articulated stairs, scaffold stairs, stairs designed into machines or equipment, and stairs on self-propelled motorized equipment. Those exclusions matter when delivery work involves both building access and vehicle access.

For fixed stairways in delivery work areas, the relevant starting point is the actual structure and its use. Paragraph (b)(7) calls for standard stairs when operations require regular and routine travel between walking-working surfaces at different levels. Paragraph (b)(8) allows spiral, ship or alternating tread stairs only when the employer demonstrates that standard stairs are not feasible.

This is a scoped reading of a federal general-industry rule. State Plans can differ, and this page alone does not establish coverage for every Virginia location or private customer property. It also does not establish a universal construction-code requirement. An assessment needs to identify the applicable requirements for the particular workplace and structure.

Identify the access structure before citing dimensions

Describe what you used in ordinary terms. A building stair flight between loading levels, steps built into a vehicle, a ladder and a dockboard should not be treated as interchangeable access structures. The stairway dimensions discussed below should not be transferred to a ladder or dockboard. If the type is uncertain, say so in the report and request identification.

Include how the access fits your assigned work. For example, explain whether it connects the area where you receive instructions with the level where you prepare a delivery load. Use your actual duties; a job title alone does not explain the route through a building. Leave the stair's installation date and technical classification marked as unknown if you have no reliable information.

Describe uneven steps in a way someone can locate

Paragraph (b)(3) requires uniform riser heights and tread depths between landings. Riser height describes the vertical step between tread surfaces; tread depth concerns the stepping surface from front to back. The uniformity requirement concerns the flight between landings, so the report should identify the affected flight as well as the individual step.

For standard stairs, paragraph (c) specifies an installation angle of 30 to 50 degrees, a maximum riser height of 9.5 inches, a minimum tread depth of 9.5 inches, and a minimum width of 22 inches between vertical barriers. Paragraph (c)(5) provides an exception to the riser-height and tread-depth provisions for standard stairs installed before January 17, 2017, with compliance alternatives stated in that paragraph. Installation history therefore matters when assessing dimensions.

Separate the observation from the measurement

State whether a step looked different, felt different during ordinary use, or was actually measured. These are different kinds of information. A report that says the last step appeared taller than the others gives the assessor a starting point. Calling it a measured dimensional failure would require evidence you may not have.

Identify the step from a clear reference point, such as the third tread above the lower landing. Include the direction you were moving. Avoid walking the flight repeatedly to reproduce an awkward step, and do not conduct a measurement that requires an unsafe position. Request that the person assessing the stairs check the dimensions and installation history.

Do not put scrap material on a tread to make it feel level or attempt to alter the step. Such a change would also alter the condition that needs assessment. Your report can be complete enough to act on while leaving measurement and repair decisions to the people assigned that work.

Include the landing and any door movement

Paragraph (b)(4) requires landings and platforms to be at least as wide as the stairs and at least 30 inches deep in the direction of travel. Paragraph (b)(5) separately addresses a door or gate opening directly onto a stairway. It requires a platform and sets minimum effective usable depths remaining through the swing: 20 inches for platforms installed before January 17, 2017, and 22 inches for those installed on or after that date.

Describe the condition when it occurs

If the concern appears only when a door opens, include that detail. Describe which way the door moves and where you were standing when you noticed the loss of space. A photograph of a closed door may miss the condition you are reporting. Do not stand in the swing path or arrange a demonstration that puts someone near the stair edge.

Distinguish the platform's apparent size from items occupying it. A report about a cart left on the landing and a report about a door reducing usable space describe different conditions. Both can be described without guessing the platform's dimensions. If you cannot tell where the landing ends, ask the assessor to establish that boundary.

Report overhead clearance and rails precisely

Paragraph (b)(2) generally requires at least 6 feet, 8 inches of vertical clearance above a tread, measured from its leading edge to an overhead obstruction. Spiral stairs have a separate requirement in paragraph (d)(3): at least 6 feet, 6 inches. Applying the general number to every stair type would miss that distinction.

For handrails, stair rail systems and guardrail systems, paragraph (b)(1) refers to section 1910.28. That cross-reference matters: use section 1910.28 to assess the required rail arrangement for a particular flight. A report can describe a missing or moving rail while leaving the applicable technical requirements to the assessment.

Name the obstruction or the part of the rail

Describe where overhead space appears restricted, such as above the uppermost tread or beneath a beam near the landing. Record whether you noticed it during ordinary travel or while carrying something. Do not estimate clearance from your own height and present the result as a measurement.

For a rail concern, identify the side while facing up the stairs and the approximate location. If a rail moved during ordinary use, describe that movement. Avoid deliberately pushing or pulling it to test its strength. You can request inspection of a missing, interrupted or moving rail without choosing the technical name for every component.

Make the report easy to assign and answer

Use your employer's reporting route if you know it. Otherwise, tell your supervisor and ask who should receive a stairway concern. At a shared worksite, provide the location to your own contact and ask who will coordinate with the person responsible for that area. Do not assume that a delivery brand or a building sign identifies the person handling maintenance.

A short written report can preserve the details after an initial conversation. Include:

• The worksite and a recognizable location for the stair flight.
• The date, approximate time and direction of travel.
• The condition you observed and the task that brought you there.
• Any uncertainty, including unmeasured dimensions or an unknown installation date.
• A request for assessment and instructions for access while the concern is unresolved.

Attach a photograph only if you can take it safely and site rules permit it. A wider view can show which flight is involved; a closer view can locate the feature. Explain what each image shows. If a photograph cannot capture movement or the way a step felt, keep that observation in the written description.

Hypothetical example: a report about the upper step

The following is an invented reporting example, not an employee account or a finding about a workplace: "At the stairs connecting the lower loading area to the upper work level, the final step before the upper landing felt higher than the preceding steps while I was walking up. I have not measured it. Please arrange an assessment and tell me which access route to use for my next trip between levels."

This example identifies the location, distinguishes a perceived difference from a measurement, and requests an operational answer. Adapt it to what you actually observed. If your concern is the door swing or a moving rail, describe that condition directly; do not add other defects to make the report sound more serious.

Obtain a usable response before the next trip

Ask who is receiving the report and when you should expect instructions. If a task requires another trip between the levels, explain when that trip is expected. A response acknowledging the message may still leave the access question unanswered, so make the request specific: identify the route or procedure you should use while the assessment is pending.

If another route is suggested, clarify where it begins and whether it is intended for your assigned task. Avoid creating your own workaround with a ladder, a vehicle or loose material. A route that looks possible from a distance may not be an authorized way to move between those work areas.

Keep the response with your original note. If it concerns a different flight, correct the location promptly. When someone reports that work has been completed, ask whether the stairs have been assessed for return to use and what instructions now apply. The repair description and the instruction for your work may arrive separately.

If the condition remains unresolved, follow up through the employer's available safety reporting route with the original report attached. State what remains observable and what answer you still need. Keep any deadline tied to the work, such as an upcoming task between levels, without inventing a regulatory response period that this source does not provide.

Clarify hiring paperwork and proposed duties

A stairway concern belongs to a particular place and task. During hiring, establish the duties you would actually perform and the employer contact who can answer access questions. Keep a question about the work area attached to that location, even when other issues in the application need separate attention.

The guide to alcohol and delivery driving addresses sober travel planning and contacting an employer when a driver cannot safely take an assignment. Clarify any proposed alternative duties, including movement between work levels. An assessed stairway and a ride to work cannot establish that a worker can safely perform those duties.

If a third-party hiring report contains an inaccurate entry, the guide to background report error explains how to locate the disputed information and contact the reporting company. Use the actual hiring paperwork for that process. Clarifying a report error and obtaining an assessment of the job's stairway access require different contacts and evidence.

Finish with a location and an access request

Before sending your report, check that someone unfamiliar with your route could find the correct stairs. Replace vague wording such as "the back steps" with the levels connected and a nearby fixed reference. Keep estimates labelled and remove conclusions that would require inspection or measurement.

Send the observation to the appropriate contact and request both an assessment and instructions for your next movement between levels. Save the response with the report. If the answer leaves the route unclear, follow up with the exact task and location before making that trip.