Regulation 38 (4) The steps of the boarding ladder shall (a) be of hardwood or other material of equivalent property made in one piece free of knots but the four lowest steps may be made of rubber of sufficient strength and stiffness, or of other suitable material of equivalent characteristics; (b) have an efficient non-slip surface; (c) be not less than 480 mm long, 115 mm wide and 23 mm in thickness, excluding any non-slip device or grooving; (d) be equally spaced and not less than 300 mm or more than 380 mm apart; and (e) be secured in a manner that it will remain horizontal.