OSHA Ladder Standard for Construction
(The most applicable rules are in blue.)
by electrician.com
OSHA Regulations (Standards - 29 CFR)
Ladders. - 1926.1053
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OSHA Regulations (Standards - 29 CFR) - Table of Contents
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Standard Number: 1926.1053
Standard Title: Ladders.
SubPart Number: X
SubPart Title: Stairways and Ladders
(a)
General. The following requirements apply to all ladders as indicated, including job-made ladders.
(a)(1)
Ladders shall be capable of supporting the following loads without failure:
(a)(1)(i)
Each self-supporting portable ladder: At least four times the maximum intended load, except that each extra-heavy-duty type 1A metal or plastic ladder shall sustain at least 3.3 time the maximum intended load. The ability of a ladder to sustain the loads indicated in this paragraph shall be determined by applying or transmitting the requisite load to the ladder in a downward vertical direction. Ladders built and tested in conformance with the applicable provisions of appendix A of this subpart will be deemed to meet this requirement.
..1926.1053(a)(1)(ii)
(a)(1)(ii)
Each portable ladder that is not self-supporting: At least four times the maximum intended load, except that each extra-heavy-duty type 1A metal or plastic ladders shall sustain at least 3.3 times the maximum intended load. The ability of a ladder to sustain the loads indicated in this paragraph shall be determined by applying or transmitting the requisite load to the ladder in a downward vertical direction when the ladder is placed at an angle of 75 1/2 degrees from the horizontal. Ladders built and tested in conformance with the applicable provisions of appendix A will be deemed to meet this requirement.
(a)(1)(iii)
Each Fixed ladder: At least two loads of 250 pounds (114 kg) each, concentrated between any two consecutive attachments (the number and position of additional concentrated loads of 250 pounds (114 kg) each, determined from anticipated usage of the ladder, shall also be included), plus anticipated loads caused by ice buildup, winds, rigging, and impact loads resulting from the use of ladder safety devices. Each step or rung shall be capable of supporting a single concentrated load of a least 250 pounds (114 kg) applied in the middle of the step or rung. Ladders built in conformance with the applicable provisions of appendix A will be deemed to meet this requirement.
(a)(2)
Ladder rungs, cleats, and steps shall be parallel, level, and uniformly spaced when the ladder is in position for use.
(a)(3)
-
(a)(3)(i)
Rungs, cleats, and steps of portable ladders (except as provided below) and fixed ladders (including individual-rung/step ladders) shall be spaced not less than 10 inches (25 cm) apart, nor more than 14 inches (36 cm) apart, as measured between center lines of the rungs, cleats and steps.
..1926.1053(a)(3)(ii)
(a)(3)(ii)
Rungs, cleats, and steps of step stools shall be not less than 8 inches (20 cm) apart, nor more than 12 inches (31 cm) apart, as measured between center lines of the rungs, cleats, and steps.
(a)(3)(iii)
Rungs, cleats, and steps of the base section of extension trestle ladders shall be not less than 8 inches (20 cm) nor more than 18 inches (46 cm) apart, as measured between center lines of the rungs, cleats, and steps. The rung spacing on the extension section of the extension trestle ladder shall be not less than 6 inches (15 cm) nor more than 12 inches (31 cm), as measured between center lines of the rungs, cleats, and steps.
(a)(4)
-
(a)(4)(i)
The minimum clear distance between the sides of individual-rung/step ladders and the minimum clear distance between the side rails of other fixed ladders shall be 16 inches (41 cm).
(a)(4)(ii)
The minimum clear distance between side rails for all portable ladders shall be 11 1/2 inches (29 cm).
(a)(5)
The rungs of individual-rung/step ladders shall be shaped such that employees' feet cannot slide off the end of the rungs.
(a)(6)
-
(a)(6)(i)
The rungs and steps of fixed metal ladders manufactured after March 15, 1991, shall be corrugated, knurled, dimpled, coated with skid-resistant material, or otherwise treated to minimize slipping.
..1926.1053(a)(6)(ii)
(a)(6)(ii)
The rungs and steps of portable metal ladders shall be corrugated, knurled, dimpled, coated with skid-resistant material, or otherwise treated to minimize slipping.
(a)(7)
Ladders shall not be tied or fastened together to provide longer sections unless they are specifically designed for such use.
(a)(8)
A metal spreader or locking device shall be provided on each stepladder to hold the front and back sections in an open position when the ladder is being used.
(a)(9)
When splicing is required to obtain a given length of side rail, the resulting side rail must be at least equivalent in strength to a one-piece side rail made of the same material.
(a)(10)
Except when portable ladders are used to gain access to fixed ladders (such as those on utility towers, billboards, and other structures where the bottom of the fixed ladder is elevated to limit access), when two or more separate ladders are used to reach an elevated work area, the ladders shall be offset with a platform or landing between the ladders. (The requirements to have guardrail systems with toeboards for falling object and overhead protection on platforms and landings are set forth in subpart M of this part.)
(a)(11)
Ladder components shall be surfaced so as to prevent injury to an employee from punctures or lacerations, and to prevent snagging of clothing.
..1926.1053(a)(12)
(a)(12)
Wood ladders shall not be coated with any opaque covering, except for identification or warning labels which may be placed on one face only of a side rail.
(a)(13)
The minimum perpendicular clearance between fixed ladder rungs, cleats, and steps, and any obstruction behind the ladder shall be 7 inches (18 cm), except in the case of an elevator pit ladder for which a minimum perpendicular clearance of 4 1/2 inches (11 cm) is required.
(a)(14)
The minimum perpendicular clearance between the center line of fixed ladder rungs, cleats, and steps, and any obstruction on the climbing side of the ladder shall be 30 inches (76 cm), except as provided in paragraph (a)(15) of this section.
(a)(15)
When unavoidable obstructions are encountered, the minimum perpendicular clearance between the centerline of fixed ladder rungs, cleats, and steps, and the obstruction on the climbing side of the ladder may be reduced to 24 inches (61 cm), provided that a deflection device is installed to guide employees around the obstruction.
(a)(16)
Through fixed ladders at their point of access/egress shall have a step-across distance of not less than 7 inches (18 cm) nor more than 12 inches (30 cm) as measured from the centerline of the steps or rungs to the nearest edge of the landing area. If the normal step-across distance exceeds 12 inches (30 cm), a landing platform shall be provided to reduce the distance to the specified limit.
..1926.1053(a)(17)
(a)(17)
Fixed ladders without cages or wells shall have a clear width to the nearest permanent object of at least 15 inches (30 cm) on each side of the centerline of the ladder.
(a)(18)
Fixed ladders shall be provided with cages, wells, ladder safety devices, or self-retracting lifelines where the length of climb is less than 24 feet (7.3 m) but the top of the ladder is at a distance greater than 24 feet (7.3 m) above lower levels.
(a)(19)
Where the total length of a climb equals or exceeds 24 feet (7.3 m), fixed ladders shall be equipped with one of the following:
(a)(19)(i)
Ladder safety devices; or
(a)(19)(ii)
Self-retracting lifelines, and rest platforms at intervals not to exceed 150 feet (45.7 m); or
(a)(19)(iii)
A cage or well, and multiple ladder sections, each ladder section not to exceed 50 feet (15.2 m) in length. Ladder sections shall be offset from adjacent sections, and landing platforms shall be provided at maximum intervals of 50 feet (15.2 m).
(a)(20)
Cages for fixed ladders shall conform to all of the following:
(a)(20)(i)
Horizontal bands shall be fastened to the side rails of rail ladders, or directly to the structure, building, or equipment for individual-rung ladders;
..1926.1053(a)(20)(ii)
(a)(20)(ii)
Vertical bars shall be on the inside of the horizontal bands and shall be fastened to them;
(a)(20)(iii)
Cages shall extend not less than 27 inches (66 cm), or more than 30 inches (76 cm) from the centerline of the step or rung (excluding the flare at the bottom of the cage), and shall not be less than 27 inches (68 cm) in width;
(a)(20)(iv)
The inside of the cage shall be clear of projections;
(a)(20)(v)
Horizontal bands shall be spaced not more than 4 feet (1.2 m) on center vertically;
(a)(20)(vi)
Vertical bars shall be spaced at intervals not more than 9 1/2 inches (24 cm) on center horizontally;
(a)(20)(vii)
the bottom of the cage shall be at a level not less than 7 feet (2.1 m) nor more than 8 feet (2.4 m) above the point of access to the bottom of the ladder. The bottom of the cage shall be flared not less than 4 inches (10 cm) all around within the distance between the bottom horizontal band and the next higher band;
(a)(20)(viii)
The top of the cage shall be a minimum of 42 inches (1.1 m) above the top of the platform, or the point of access at the top of the ladder, with provision for access to the platform or other point of access.
..1926.1053(a)(21)
(a)(21)
Wells for fixed ladders shall conform to all of the following:
(a)(21)(i)
They shall completely encircle the ladder;
(a)(21)(ii)
They shall be free of projections;
(a)(21)(iii)
Their inside face on the climbing side of the ladder shall extend not less than 27 inches (68 cm) nor more than 30 inches (76 cm) from the centerline of the step or rung;
(a)(21)(iv)
The inside clear width shall be at least 30 inches (76 cm);
(a)(21)(v)
The bottom of the wall on the access side shall start at a level not less than 7 feet (2.1 m) nor more than 8 feet (2.4 m) above the point of access to the bottom of the ladder.
(a)(22)
Ladder safety devices, and related support systems, for fixed ladders shall conform to all of the following:
(a)(22)(i)
They shall be capable of withstanding without failure a drop test consisting of an 18-inch (41 cm) drop of a 500-pound (226 kg) weight;
(a)(22)(ii)
They shall permit the employee using the device to ascend or descend without continually having to hold, push, or pull any part of the device, leaving both hands free for climbing;
..1926.1053(a)(22)(iii)
(a)(22)(iii)
They shall be activated within 2 feet (.61 m) after a fall occurs, and limit the descending velocity of an employee to 7 feet/sec. (2.1 m/sec.) or less;
(a)(22)(iv)
The connection between the carrier or lifeline and the point of attachment to the body belt or harness shall not exceed 9 inches (23 cm) in length.
(a)(23)
The mounting of ladder safety devices for fixed ladders shall conform to the following:
(a)(23)(i)
Mountings for rigid carriers shall be attached at each end of the carrier, with intermediate mountings, as necessary, spaced along the entire length of the carrier, to provide the strength necessary to stop employees' falls;
(a)(23)(ii)
Mountings for flexible carriers shall be attached at each end of the carrier. When the system is exposed to wind, cable guides for flexible carriers shall be installed at a minimum spacing of 25 feet (7.6 m) and maximum spacing of 40 feet (12.2 m) along the entire length of the carrier, to prevent wind damage to the system.
(a)(23)(iii)
The design and installation of mountings and cable guides shall not reduce the design strength of the ladder.
..1926.1053(a)(24)
(a)(24)
The side rails of through or side-step fixed ladders shall extend 42 inches (1.1 m) above the top of the access level or landing platform served by the ladder. For a parapet is continuous, the access level shall be the top of the parapet.
(a)(25)
For through-fixed-ladder extensions, the steps or rungs shall be omitted from the extension and the extension of the side rails shall be flared to provide not less than 24 inches (61 cm) nor more than 30 inches (76 cm) clearance between side rails. Where ladder safety devices are provided, the maximum clearance between side rails of the extensions shall not exceed 36 inches (91 cm).
(a)(26)
For side-step fixed ladders, the side rails and the steps or rungs shall
be continuous in the extension.
(a)(27)
Individual-rung/step ladders, except those used where their access openings are covered with manhole covers or hatches, shall extend at least 42 inches (1.1 m) above an access level or landing platform either by the continuation of the rung spacings as horizontal grab bars or by providing vertical grab bars that shall have the same lateral spacing as the vertical legs of the rungs.
(b)
Use. The following requirements apply to the use of all ladders, including job-made ladders, except as otherwise indicated:
..1926.1053(b)(1)
(b)(1)
When portable ladders are used for access to an upper landing surface, the ladder side rails shall extend at least 3 feet (.9 m) above the upper landing surface to which the ladder is used to gain access; or, when such an extension is not possible because of the ladder's length, then the ladder shall be secured at its top to a rigid support that will not deflect, and a grasping device, such as a grabrail, shall be provided to assist employees in mounting and dismounting the ladder. In no case shall the extension be such that ladder deflection under a load would, by itself, cause the ladder to slip off its support.
(b)(2)
Ladders shall be maintained free of oil, grease, and other slipping hazards.
(b)(3)
Ladders shall not be loaded beyond the maximum intended load for which they were built, nor beyond their manufacturer's rated capacity.
(b)(4)
Ladders shall be used only for the purpose for which they were designed.
(b)(5)
-
(b)(5)(i)
Non-self-supporting ladders shall be used at an angle such that the horizontal distance from the top support to the foot of the ladder is approximately one-quarter of the working length of the ladder (the distance along the ladder between the foot and the top support).
(b)(5)(ii)
Wood job-made ladders with spliced side rails shall be used at an angle such that the horizontal distance is one-eighth the working length of the ladder.
(b)(5)(iii)
Fixed ladders shall be used at a pitch no greater than 90 degrees from the horizontal, as measured to the back side of the ladder.
..1926.1053(b)(6)
(b)(6)
Ladders shall be used only on stable and level surfaces unless secured to prevent accidental displacement.
(b)(7)
Ladders shall not be used on slippery surfaces unless secured or provided with slip-resistant feet to prevent accidental displacement. Slip-resistant feet shall not be used as a substitute for care in placing, lashing, or holding a ladder that is used upon slippery surfaces including, but not limited to, flat metal or concrete surfaces that are constructed so they cannot be prevented from becoming slippery.
(b)(8)
Ladders placed in any location where they can be displaced by workplace activities or traffic, such as in passageways, doorways, or driveways, shall be secured to prevent accidental displacement, or a barricade shall be used to keep the activities or traffic away from the ladder.
(b)(9)
The area around the top and bottom of ladders shall be kept clear.
(b)(10)
The top of a non-self-supporting ladder shall be placed with the two rails supported equally unless it is equipped with a single support attachment.
(b)(11)
Ladders shall not be moved, shifted, or extended while occupied.
..1926.1053(b)(12)
(b)(12)
Ladders shall have nonconductive siderails if they are used where the employee or the ladder could contact exposed energized electrical equipment, except as provided in 1926.951(c)(1) of this part.
(b)(13)
The top or top step of a stepladder shall not be used as a step.
(b)(14)
Cross-bracing on the rear section of stepladders shall not be used for climbing unless the ladders are designed and provided with steps for climbing on both front and rear sections.
(b)(15)
Ladders shall be inspected by a competent person for visible defects on a periodic basis and after any occurrence that could affect their safe use.
(b)(16)
Portable ladders with structural defects, such as, but not limited to, broken or missing rungs, cleats, or steps, broken or split rails, corroded components, or other faulty or defective components, shall either be immediately marked in a manner that readily identifies them as defective, or be tagged with "Do Not Use" or similar language, and shall be withdrawn from service until repaired.
(b)(17)
Fixed ladders with structural defects, such as, but not limited to, broken or missing rungs, cleats, or steps, broken or split rails, or corroded components, shall be withdrawn from service until repaired. The requirement to withdraw a defective ladder from service is satisfied if the ladder is either:
..1926.1053(b)(17)(i)
(b)(17)(i)
Immediately tagged with "Do Not Use" or similar language;
(b)(17)(ii)
Marked in a manner that readily identifies it as defective;
(b)(17)(iii)
Or blocked (such as with a plywood attachment that spans several rungs).
(b)(18)
Ladder repairs shall restore the ladder to a condition meeting its original design criteria, before the ladder is returned to use.
(b)(19)
Single-rail ladders shall not be used.
(b)(20)
When ascending or descending a ladder, the user shall face the ladder.
(b)(21)
Each employee shall use at least one hand to grasp the ladder when progressing up and/or down the ladder.
(b)(22)
An employee shall not carry any object or load that could cause the
employee to lose balance and fall.
[55 FR 47689, Nov. 14, 1990; 56 FR 2585, Jan. 23, 1991; 56 FR 41794, Aug. 23, 1991]
Interpretations
May 11, 1999
J. Nigel Ellis, Ph.D., CSF, P.E., CPE
President
Dynamic Scientific Controls
P.O. Box 445
Wilmington, Delaware 19899-0445
Dear Mr. Ellis:
This is in response to your letter of March 18, 1998 in which you raised several issues "for answer now where possible but also intended for [inclusion in the Advanced Notice of Proposed Rulemaking on Subpart M]." We apologize for the long delay in answering your letter. We have answered several of your questions below. With respect to the others, we will consider including the issues they raise in our upcoming Advance Notice of Proposed Rulemaking for Subparts M (fall protection) and L (scaffolds).
The difference between maintenance and construction
Your first question is whether painting a power pole is maintenance
or construction work. In your example the poles are painted "periodically
between ten and twenty years." You ask if the following factors bear on
whether the work is maintenance or construction: (1) whether the work is
done by an outside contractor rather than by a power company’s own employees;
(2) if the poles are painted while major parts of the pole are live; (3)
if painting the poles is a regular part of the employee’s work, and (4)
type of tower (pole or lattice).
If the painting of the poles is an anticipated, routine, and periodic event to keep them from degrading and to maintain them in their original condition, then the painting is maintenance work. The fact that 10 or 20 years transpires between repainting would not normally alter this conclusion, as long as the repainting continues to be a scheduled activity. The following factors do not affect whether the work is considered maintenance or construction: whether the work is done by the power company or by an outside contractor; parts of the tower are live; painting the poles is a regular part of the employee’s work and whether the tower is of a pole or lattice configuration.
When painting or welding is done as a construction activity, do OSHA regulations permit the work to be done while standing on one foot on an offset step (climbing) single rail ladder?
No; §1926.1053(b)(19) prohibits the use of single rail ladders.
Is working (other than climbing activity or accessing) from any fixed ladder permitted? Does this depend on whether fall protection is provided?
First, under §1926.1053(a)(19), fall protection must be provided – whether the employee is climbing (up or down) or working from a ladder – whenever the length of climb equals or exceeds 24 feet. Also, even if the length of climb is less than 24 feet, under §1926.1053(a)(18), cages, wells, ladder safety devices, or self-retracting lifelines must be provided where the top of the ladder is greater than 24 feet above lower levels.
Second, §1926.1053 (b)(4) provides that "ladders shall be used only for the purpose for which they were designed." For those situations where §1926.1053 does not require fall protection, an employee may work from a fixed ladder without fall protection only where that work is consistent with the purpose for which the ladder was designed. Most vertical, fixed ladders were not designed to work from with both hands off the ladder.
In addition, as explained in the next answer, a cage or well is usually designed to provide fall protection while moving up or down the ladder – not while working with both hands off the ladder.
If a worker leans out from a fixed ladder while working and uses the ladder safety system for support, must the employer protect the worker with an additional fall protection device?
Most ladder safety systems (vertical lifeline type systems) are not designed to support a worker leaning out from the ladder; they are usually designed to protect a worker while fully on the ladder. Also, a cage or well is not designed to provide fall protection for a worker using the cage or well for support, or working with both hands off the ladder. Using such ladder safety systems, cages or wells for support would violate §1926.1053(b)(4).
In the type of situation you describe, if the worker cannot perform the work with both feet and one hand on the ladder, the employee will have to be protected by more than a harness and lanyard connected to a ladder safety device. The tie-off type support would have to meet the requirements of a boatswain’s chair or other single point adjustable scaffold. The requirements for these devices are listed in §1926.452(o).
Is climbing a single rail ladder permitted on a tank or power pole under 1926.1053(b)(19)?
No. Section 1926.1053(b)(19) prohibits the use of single rail ladders.
Does 1926.502(d)(20) require a second person to be present for rescue purposes?
Not necessarily. Section 1926.502(d)(20) states that "the employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves." The particular hazard that Section 1926.502(d)(20) addresses is being suspended by the fall arrest system after an arrested fall. While an employee may be safely suspended in a body harness for a longer period than a body belt, "prompt" requires that rescue be performed quickly -- in time to prevent serious injury to the worker. There are a wide range of ways in which this requirement can be met, depending on the particular circumstances of the work site. For example, a single worker equipped with communication equipment that enables the worker to obtain help promptly would meet the requirement.
If you need further assistance, please write to: Directorate of Construction - OSHA Office of Construction Standards and Compliance Assistance, Room N3467, 200 Constitution Avenue, N.W., Washington, D.C. 20210.
Sincerely,
Russell B. Swanson, Director
Directorate of Construction
June 2, 1998
Mr. Gregory C. Clemens
Roofmaster Products Company
P. O. Box 6339
Los Angeles, CA 90063-0309
Re: 1926.500-503; 1926.552; 1926.1053
Dear Mr. Clements:
This is in response to your letter dated October 4, 1995, requesting an interpretation of the Occupational Safety and Health Administration (OSHA) standards addressing ladders used to support a hoisting wheel. Your letter references the use of a Ladder Master Hoisting Wheel, and the need to adhere to the regulations for ladder use while involved in lifting materials with this device.
Ladders are required to be secured to prevent accidental displacement when employees are using them on unstable, slippery or non level surfaces. However, when using a ladder to lift materials with a hoisting wheel, employees would not be using the ladder for climbing and therefore would not be subjected to ladder use requirements.
When involved in this lifting activity, the ladder would not be considered a hoist for the purposes of OSHA's hoisting regulations and would therefore not be subject to the provisions of Subpart N-Cranes, Derricks, Hoists, Elevators, and Conveyors. However, those employees exposed to fall hazards during lifting activities must comply with the applicable fall protection requirements in accordance with 29 CFR 1926.500-503, (e.g. safety monitor for low sloped roofs).
We agree, if used properly and within manufacturer's guidelines, this ladder hoisting wheel could reduce or eliminate injuries from lifting heavy loads while climbing ladders.
Thank you for your interest in job site safety and health issues and if we can be of any further assistance, please write to:
Directorate of Construction-OSHA
Office of Construction Standards and
Compliance Assistance, Rm. N3621
200 Constitution Avenue, N.W.- Rm. N3621
Washington, D.C. 20210
Sincerely,
Russell B. Swanson, Director
Directorate of Construction
October 4, 1995
Mr. Roy F Gurnham
U. S. Department of Labor
Occupational Safety and Health Administration
Washington. D.C. 20210
Re: Ladders as a hoist
Dear Mr. Gurnham:
A product called the Ladder Master Hoisting Wheel has been sold into the construction trades for decades. It is placed on the inside rungs (toward the building) for hoisting light loads to the roof edge.
The worker on the roof grasps the handle end and pushes the ladder outward to his arms length (the handle is 24" long). The worker on the ground, standing outside of the rungs so he is not under the load, pulls the load up using a 3/4" manila rope.
Ladder mounted hoisting wheels are manufactured for both round rung and flee rung ladders. Warning labels indicate that they are not to be used for loads exceeding the rating of the ladder
Here is our problem:
A roofer in the Carolinas phoned today to say that he was confused. He acknowledges that he must tie-off his ladder when his workers use it to more from one level to another. When he then wants to use his ladder as a hoist, using the ladder mounted hoisting wheel, he cannot comply with this provision since he could not raise the load.
When he installs the hoisting device on the ladder, it is no longer a ladder, it is now a hoist. At this point. his hoist should be subject to safety provisions other than the ladder tie-off rule.
Perhaps at this point, he would be subject to 29 CFR 1926.501(b)(3) under the duty to have fall protection in a hoist area.
The use of these wheels is widespread. As the manufacturer, we would like lo issue proper information and if needed create new safety labels for these products. The use of ladder mounted hoisting wheels saves many a worker from back injury, while allowing them to focus on the job of climbing a ladder, not carrying a load up or down the ladder.
Thank you for your attention to this issue.
Kind regards,
Larry Clemens
August 7, 1997
Mr. Lynn A. Warren
Safety Supervisor
Custodis-Ecodyne, Inc.
Route 1, Box 1256
Barnsdall, OK 74002
Dear Mr. Warren:
This is in response to your letter of November 26, 1996, to the Occupational Safety and Health Administration (OSHA) in which you requested an opinion on OSHA's requirements for enclosed hardware used in 'third rail' ladder safety devices for towers. I apologize for the delay in this response.
OSHA has no standard that specifically requires fixed ladders to be installed on communication towers and, hence, no standard that requires ladder safety devices to be provided on communication towers without fixed ladders.
OSHA's safety and health standards for construction (29 CFR Part 1926) require fall protection for employees on communications towers (1926.105) where the fall distance exceeds 25 feet. Under the fixed ladder provisions [1926.1053(a)(18)], OSHA requires that fixed ladders be equipped with cages, wells, ladder safety devices or self-retracting lifelines. Please note that these requirements apply only for construction activities.
The safety and health standards for general industry (29 CFR Part 1910) contain fall protection requirements for non-construction work activities such as maintenance on communication towers. For example, workers must be protected from falling from communication towers under 1910.268. Section 1910.27 contains requirements for fixed ladders, such as ladder safety devices or cages.
You may be interested to know that OSHA has been in communication with the National Association of Tower Erectors (NATE) regarding hazards associated with both the construction and the maintenance phase of communications towers. NATE has provided information to OSHA regarding the industry's view on appropriate fall protection measures. That information will be discussed in an upcoming rulemaking action to be conducted by the Agency to revise the construction fall protection requirements (Subpart M). It is expected that Subpart M will be officially opened for comment in the Federal Register last in 1997.
I have enclosed a copy of the Federal Register of April 10, 1990, which proposes a revision to the general industry standard for ladders. As you can see, it discusses the use of ladder safety devices and other measures of protecting workers from falling from towers during maintenance activities. For additional information on this proposed general industry rule, please contact Mr. Chap Pierce of the Directorate of Safety Standards Programs at (202) 219-7216 or by writing to him at U.S. Department of Labor (OSHA), Directorate of Safety Standards Programs, Room N3621, 200 Constitution Avenue, N.W., Washington, D.C. 20210.
Sincerely,
Russell B. Swanson, Director
Directorate of Construction
April 2, 1996
J. Nigel Ellis, Ph.D., CSP, P.E., CPE
President
Dynamic Scientific Controls
P.O. Box 445
Wilmington, DE 19899-0445
Dear Dr. Ellis:
This is in response to your letter of January 28, in which you requested several interpretations relative to portable ladders. Your questions and the relevant responses for general industry and construction are:
Is it true that: 1. Portable ladders are any ladders which are transportable by any means not just physical carrying?
Answer (General Industry): 29 CFR 1910.21(e)(2) defines fixed ladders as "a ladder permanently attached to a structure, building, or equipment." Portable ladders are not defined in the standard, but by inference, a portable ladder would be any ladder not fitting the definition of a fixed ladder. The ANSI standard A14.2-1990 defines a portable ladder as "a ladder that can readily be moved or carried, usually consisting of side rails joined at intervals by step, rungs, cleats, or rear braces."
Answer (Construction): 29 CFR 1926.1050 defines a fixed ladder as "a ladder that cannot be readily moved or carried because it is an integral part of a building or structure." A portable ladder is defined as "a ladder that can be readily moved or carried." Also, by inference, a portable ladder would be one that is not an integral part of a building or structure.
2. Stacked and scaling ladders must have fall protection over a certain height, even if they are physically removable by crane and even though they are less than 20ft length in individual piece length (and never joined), and when they are positioned vertically (or steeper than 4:1 angle)?
Answer (General Industry): If these ladders do not fit the definition of fixed ladders as defined above, they would be deemed as portable ladders, and, therefore, not required to have fall protection. If they are fixed ladders, they are required to have fall protection at a length of 24ft. (OSHA proposed rule 29 CFR 1910.23(c)(14)). Such a determination would have to be made on a case-by-case basis, per inspection. The proposed rule also provides for exemption from fall protection requirements for "qualified climbers" as provided in 1910.32(b)(5).
Answer (Construction): Scaling ladders often combine features of fixed and portable ladders. By definition, stacked or scaling ladders are portable ladders. The specific provisions for portable ladders address fall protection concerns primarily by requiring the ladder to be used at a four to one angle (29 CFR 1926.1053(b)(5)(i)). This provision is intended to address ladder stability. The stability could be addressed by how it is attached to the structure. The ladder assembly would need to be judged on a case-by-case basis to determine if it would be considered a fixed ladder and if fall protection is needed.
3. Scaffold ladders independently added to a scaffold or between tank brackets whether designed by the scaffold manufacturer or not, must have fall protection over a certain height fall exposure?
Answer (General Industry): There is no requirement for fall protection on scaffold ladders under the general industry standard.
Answer (Construction): There is no requirement for fall protection on scaffold ladders under the construction standard. Scaffolds must have rest platforms, however. Scaffold access is governed by Subpart L.
4. When ladders are used to work from as opposed to access from, fall protection must be applied according to 1926.500 and the equivalent general industry standards?
Answer (General Industry): Again, if the ladder in question is a portable ladder, there is no requirement for fall protection. If it is a fixed ladder, it will depend upon the conditions specified in the standard, i.e., is the climber a "qualified climber"? Is the height over 24ft? When not required, it is advisable, if feasible, however, to have fall protection when the worker doesn't have at least one hand available to hold on to the ladder.
Answer (Construction): Ladder use is governed by 1926.1053(b), not 1926.500.
Sincerely,
John B. Miles, Jr., Director
Directorate of Compliance Programs
October 5, 1995
Mr. Robert M. Hull
Stage One Inc.
615 W. Olive Street
Bloomington, IL 61781
Dear Mr. Hull:
This is in response to your September 18 letter requesting a letter of compliance from the Occupational Safety and Health Administration for your ladder stand-off with handrails device (1926.1053(b)(1)).
As you may know, OSHA does not endorse products nor issue formal letters of approval for products or procedures. However, when provided with sufficient information, OSHA can offer an opinion as to whether or not they afford compliance with certain regulations. We have reviewed the Belle Ladder Stand-off product data enclosed in your letter and it appears that if your device is properly attached to the ladder and roof it would meet or exceed the requirements of 1926.1053(b)(1).
If we can be of further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.
Sincerely,
Roy F. Gurnham, P.E., J.D.
Director
Office of Construction and Maritime
Compliance Assistance
August 3, 1992
MEMORANDUM FOR: JOHN B. MILES, JR.
REGIONAL ADMINISTRATOR
LEO CAREY, DIRECTOR OFFICE OF FIELD
PROGRAMS
FROM:
PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Specialty Ladders Used in Manholes
This is in response to your March 3 memorandum requesting an interpretation
as to whether or not ladders, designed to be used in manhole applications,
must comply with the OSHA's construction and general industry side rail
width requirements. I apologize for the delay in responding to your inquiry.
In his February 5 letter to you, Mr. Kline of Lynn Ladder and Scaffolding
Company stated that a ladder meeting the width requirements of Subpart
X will not offer safe access into 24-inch diameter manholes. In order for
us to make a determination that compliance with this standard is unsafe,
more information is needed. Please provide to us an analysis or clearance
comparison of the two different width ladders when used to access 24-inch
manholes.
If we can be of any further assistance, please contact Mr. Rolland Stroup in the Office of General Industry Compliance Assistance on (202) 523-8031 or Mr. Dale Cavanaugh in the Office of Construction and Maritime Compliance Assistance on (202) 523- 8124.
April 2, 1992
Mr. Randy Hooks President
Lydich-Hooks Roofing Company
Post Office Box 2605
Lubbock, Texas 79408
Dear Mr. Hooks:
This is in response to your January 13 letter to the Occupational Safety and Health Administration's (OSHA) Lubbock Area Office requesting a variance from the ladder use requirement of 29 CFR 1926.1053(b)(22). Your request has been forwarded to this office for response. I apologize for the delay in responding to you.
OSHA is unable to grant your request for a variance from the requirements of 1926.1053(b)(22) because this section allows an object or load to be carried by a person climbing or descending a ladder provided it is done safely (so as not to cause the employee to lose balance and fall). In regard to which objects can be carried safely, please be guided by the following discussion from the preamble of the final rule (55 FR 47682) which was published on November 14, 1990:
"Although OSHA believes that small items such as hammers, pliers, measuring tapes, nails, paint brushes, and similar items should be carried in pouches, holsters, or belt loops, the language in the final rule would not preclude an employee from carrying such items while climbing a ladder so long as the items don't impede the employee's ability to maintain full control while climbing or descending the ladder. It is OSHA's belief that the employee's focus and attention while climbing up and/or down a ladder should be on making a safe ascent or descent and not on transporting items up and down the ladder. OSHA notes that an employee who needs to take a large or heavy object to a different level by means of a ladder can pull the object up or lower it with a handline."
If we can be of any further assistance, please contact Mr. Roy F. Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 523-8136.
Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs
January 13, 1992
U.S. Department of Labor
Occupational Safety & Health Administration
Room 422,
Federal Building
1205 Texas Avenue
Lubbock, Texas 79401
Re: 29 CFR 1926.1053(b)(22)
Gentlemen:
We hereby request a permanent variance from the above-referenced standard. The record will show that for our company the risks from the above-referenced hazard have been non-existent.
We take great care in training our personnel in ladder safety. The risks that we would incur in utilizing other methods of material conveyance seem to expose our employees to greater risk than simply carrying something up a ladder.
The statute as written seems a little vague. The working or the statute implies that there are objects or loads which could be carried safety. In short, this subpart seems to be judging. We submit that our employees should be allowed to occasionally carry materials up ladders without threat of citation.
Please let us know your views on our Variance Application.
Yours truly,
LYDICK-HOODS ROOFING COMPANY OF LUBBOCK, INC.
Randy Hooks
President
RE: bf
December 6, 1991
Mr. Sidney Freedman
Director
Architectural Precast Concrete Services
175 West Jackson Blvd.
Chicago, Illinois 60604
Dear Mr. Freedman:
Your letter of September 12 to Ms. Barbara Bielaski requesting suggestions for the protection of workers on ladders performing initial connecting work has been forwarded to the Office of Construction and Maritime Compliance Assistance for reply. I apologize for the delay in responding to your inquiry.
In respect to the use of ladders positioned against columns on the side of structures as illustrated in the pictures accompanying your letter, OSHA requires the base of the ladder be secured if used on a slippery concrete surface (29 CFR 1926.1053(b)(7)) and that rails at the top of the ladder be supported equally (29 CFR 1926.1053(b)(10)). As an added precaution, body belt/harness systems could be rigged to lifelines attached to the columns, or means could be provided to secure the top of the ladder in place by the use of a wide fork-like attachment at the top of the ladder that would overlap the sides of the column to prevent the ladder from sliding off the column.
With regard to employees who are not on ladders, the general fall protection requirements of Part 1926, Subparts E and M and Section 5(a)(1) of the Act apply.
If we can be of any further assistance, please contact Mr. Roy F. Gurnham or Mr. Dale R. Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 523-8124.
Sincerely,
Patricia K. Clark
Director
Directorate of Compliance Programs
September 12, 1991
Ms. Barbara Bielaski
OSHA, U. S. Department of Labor
Room N-3621
200 Constitution Avenue, N.W.
Washington, DC 20210
Dear Ms. Bielaski:
The question arose at our last Erection Safety meeting as to the best means of protection for the initial connectors placing the ledger beams on the columns.
The enclosed pictures show the connector standing on a ladder. In other cases, an elevating and rotating work platform can be used, except possibly in multistory (10-15 stories) construction.
Any suggestions that you might have for available means of protection for the worker on the ladder would be appreciated.
Very truly yours,
Sidney Freedman, Director
Architectural Precast Concrete Services
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