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Working At Elevated Heights

Are Your Ladders Compliant? OSHA and ANSI Ladder Requirements

10/1/20
Quick Tips #132.1

According to OSHA, falls from ladders account for 20% of all fatal and lost workday injuries in general industry. A critical component of fall prevention is making sure all your ladders meet OSHA and ANSI-ASC standards. Read on to see if yours pass the test.

Ladders come in a variety of shapes, sizes and materials. They are useful in many industries for a variety of applications. This document offers an overview of the Occupational Safety and Health Administration (OSHA) and the American National Standards Institute (ANSI) Accredited Standards Committee (ASC) standards for ladders, along with tips for proper ladder usage.

OSHA Regulatory Requirements

In late 2016, OSHA published an update to its walking-working surface rule (subpart D) for general industry. Subpart D applies to all general industry workplaces and covers all walking-working surfaces unless specifically excluded by an individual section of the subpart. Specifically, the update incorporates advances in technology, industry best practices and national consensus standards to provide effective and cost-efficient worker protection addressing slip, trip and fall hazards.

As part of the update, OSHA combined its previously separate regulations for portable wood ladders, portable metal ladders and fixed ladders under one comprehensive ladder standard:  29 Code of Federal Regulations (CFR) 1910.23 applies to all ladders used in general industry with a few exceptions. Those exceptions are ladders used in emergency operations such as firefighting, rescue and tactical law enforcement operations, or training for those operations, and ladders that are an integral part of a machine or piece of equipment.

The four main components of OSHA’s ladder standard cover:

  • General Requirements
  • Portable Ladders
  • Fixed Ladders
  • Mobile Ladder Stands and Mobile Ladder Stand Platforms

Under the General Requirements (29 CFR 1910.23(b)), OSHA addresses proper ladder climbing technique. It requires that when ascending or descending a ladder, employees must always maintain three points of contact by:

  • Facing the ladder
  • Using at least one hand to firmly grasp the ladder
  • Not carrying any object or load that could cause them to lose balance and fall

Employers are required to ensure that every employee follows this climbing technique.
The General Requirements also cover the design specifications for rungs and steps used on ladders and stepstools. Except for ladders used in elevator shafts and communication towers, the design for rungs and steps must meet the following criteria:

General Requirements – Ladder Rungs, Steps and Cleats
Parallel, level and uniformly spaced when the ladder is in position for use.
Spaced not less than 10 inches and not more than 14 inches apart.
Minimum clear width of 11.5 inches on portable ladders and 16 inches for fixed ladders.
Manhole entry ladders rungs and steps supported by the manhole opening must have a minimum clear width of nine inches.
Telecommunication center rolling ladders rungs and steps must have a minimum clear width of eight inches.
Step stools must have a minimum clear width of 10.5 inches.

In addition, the General Requirements mandate the following:

General Requirements
Wooden ladders must not be coated with any material that may obscure structural defects.
Metal ladders must be made with corrosion-resistant material or protected against corrosion.
Ladder surfaces must be free of puncture and laceration hazards.
Ladders must only be used for the purpose for which they were designed.
Ladders must be inspected before initial use in each work shift, and more frequently as necessary, to identify any visible defects that could cause employee injury.
Any ladder with structural or other defects must be immediately tagged "Dangerous: Do Not Use," or with similar language in accordance with 29 CFR 1910.145, and removed from service until repaired in accordance with 29 CFR 1910.22(d) or replaced.

Portable Ladders
OSHA defines a portable ladder as one that can readily be moved or carried, usually consisting of side rails joined at intervals by steps, rungs, or cleats.(29 CFR 1910.21).
In accordance with 29 CFR 1910.23(c), employers must ensure that:

Portable Ladders
Rungs and steps are slip resistant.
Ladders are equipped with a metal spreader or locking device that securely locks ladder in open position.
Ladders are not loaded beyond maximum intended load.
No single rail ladders are used.
Ladders are secured to prevent accidental displacement or guarded by a temporary barricade when used in passageways, doorways or driveways.
Ladders are secured and stabilized if used on slippery surfaces.
Ladders are not moved, shifted or extended while being used.
Top step and caps of stepladders are not used as steps.
If used to gain access to upper landing surface, the side rails extend at least three feet above the upper landing surface.
Ladders are not fastened together to provide added length unless designed for such use.
Ladders are not placed on boxes, barrels, or other unstable bases to obtain added height.

Fixed Ladders

OSHA defines a fixed ladder as a ladder with rails or individual rungs that is permanently attached to a structure, building or equipment (29 CFR 1910.21). These do not include ship stairs, step bolts, or manhole steps.
OSHA gets more granular with design requirements for specific types of fixed ladders above and beyond what’s specified under the General Requirements. Employers must ensure that:

 

Fixed Ladders
Ladders can support their maximum intended load.
The minimum perpendicular distance from the centerline of the steps or rungs, or grab bars, or both, to the nearest permanent object behind the ladder is 7 inches, except for elevator pit ladders, which have a minimum perpendicular distance of 4.5 inches.
Grab bars do not protrude on the climbing side beyond the rungs of the ladder that they serve.
The side rails of through or sidestep ladders extend 42 inches above the top of the access level or landing platform served by the ladder.
For through ladders, the steps or rungs are omitted from the extensions, and the side rails are flared to provide not less than 24 inches and not more than 30 inches of clearance (when a ladder safety system is provided, the maximum clearance between side rails of the extension must not exceed 36 inches).
For side-step ladders, the side rails, rungs, and steps are continuous in the extension.
Grab bars extend 42 inches above the access level or landing platforms served by the ladder.
The minimum cross-section size of grab bars is the same size as the rungs of the ladder.
When a fixed ladder terminates at a hatch, the hatch cover opens with enough clearance to provide easy access to or from the ladder, and opens at least 70° from horizontal if the hatch is counterbalanced.
Individual-rung ladders are constructed to prevent the employee's feet from sliding off the ends of the rungs.
Ladders having a pitch greater than 90° from the horizontal are not used.
The step-across distance from the centerline of the rungs or steps for through ladders, is not less than 7 inches and not more than 12 inches to the nearest edge of the structure, building, or equipment accessed from the ladders.
The step-across distance from the centerline of the rungs or steps for side-step ladders is not less than 15 inches and not more than 20 inches to the access points of the platform edge.
Ladders that do not have cages or wells have a clear width of at least 15 inches on each side of the ladder centerline to the nearest permanent object and a minimum perpendicular distance of 30 inches from the centerline of the steps or rungs to the nearest object on the climbing side (when unavoidable obstructions are encountered, the minimum clearance at the obstruction may be reduced to 24 inches provided deflector plates are installed).

OSHA’s updated walking-working surfaces rule also addresses fixed ladders under 29 CFR 1910.28(b)(9), Duty to Have Fall Protection and Falling Object Protection. The rule phases in, over 20 years, a requirement to equip fixed ladders (that extend over 24 feet above a lower level) with ladder safety or personal fall arrest systems, and it prohibits the use of cages and wells as a means of fall protection after the phase-in deadlines. The rule grandfathers in cages and wells on existing ladders but requires that employers equip new ladders and replacement ladders/ladder sections with ladder safety or personal fall arrest systems during the phase-in period. Shown below are the established phase-in dates:

Fixed Ladders (Extending More Than 24 Feet Above a Lower Level)
After January 17, 2018 Any section/portion of an existing fixed ladder that is replaced must be equipped with a ladder safety or personal fall arrest system - may also install new cages/wells along with the ladder safety or personal fall arrest system if there is no interference.
Erected before November 19, 2018 Employers have up to 20 years to install ladder safety or personal fall arrest systems.
Erected on/or after November 19, 2018 Employers must equip the ladder with a ladder safety or personal fall arrest system.
After November 18, 2036 All fixed ladders must be equipped with a ladder safety or personal fall arrest system.

Mobile Ladder Stands and Mobile Ladder Stand Platforms
OSHA defines a mobile ladder stand as a mobile, fixed-height, self-supporting ladder that usually consists of wheels or casters on a rigid base and steps leading to a top step (29 CFR 1910.21). A mobile ladder stand may also have handrails and is designed for use by one employee at a time. OSHA defines a mobile ladder stand platform as a mobile, fixed-height, self-supporting unit having one or more standing platforms that are provided with means of access or egress.

Per 29 CFR 1910.23(e) employers must ensure that mobile ladder stands and mobile ladder stand platforms: General Requirements – Mobile Ladder Stands and Platforms
Have a step width of at least 16 inches.
Have slip resistant steps and platforms.
Can support at least four times their maximum intended load.
Wheels or casters under load can support their proportional share of four times the maximum intended load, plus their proportional share of the unit's weight.
With a top step height of 4-feet or above have handrails with a vertical height of 29.5 to 37-inches, measured from the front edge of a step - removable gates or non-rigid members, such as chains, may be used instead of handrails in special-use applications.
Maximum work-surface height does not exceed four times the shortest base dimension, without additional support - stabilizing outriggers, counterweights, or comparable means to prevent overturning must be used for greater heights.
Have wheels or casters equipped with a system to impede horizontal movement when an employee is on it.
 

 

Design Requirements – Mobile Ladder Stands and Platforms
Stand and platform steps are uniformly spaced and arranged, with a rise of not more than 10-inches and a depth of not less than 7-inches, and the slope of the step stringer is less than 60-degrees, measured from the horizontal.
When the step spacing and arrangement is not feasible for platforms, stabilized units (to prevent overturning) with steeper slopes or vertical rung ladders are used.
Stands with a top step height above 10-feet, have the top step protected on three sides by a handrail with a vertical height of at least 36-inches and top steps that are 20-inches or more, front to back, have a midrail and toeboard. Removable gates or non-rigid members, such as chains, may be used instead of handrails in special-use applications.
Stands standing area is within the base frame.
Platforms with a platform height of 4 to 10-feet have, in the platform area, handrails with a vertical height of at least 36-inches and midrails – removable gates or non-rigid members, such as chains, may be used instead of handrails in special-use applications.
Platforms with a platform height above 10-feet have guardrails and toeboards on the exposed sides and ends of the platform - removable gates or non-rigid members, such as chains, may be used instead of guardrails in special-use applications.

ANSI-ASC Portable Ladder Standards

American National Standards Institute (ANSI) – Accredited Standards Committee consensus standards for portable ladders detail the materials, safe construction, design, testing, care and use, and labeling/marking for various types and styles of portable ladders, and include:

Ladder Styles and Types

Portable ladder styles include ladder type step stools, portable extension, step trestle, sectional, combination, single, platform, articulating, articulating extendable, and telescoping ladders.

Ladder types are shown below:

Duty Rating Ladder Type Working Load (Pounds)
Special Duty IAA 375
Extra Heavy Duty IA 300
Heavy Duty I 250
Medium Duty II 225
Light Duty III 200

Material Guidelines

ANSI recommends various species of wood that are suitable for ladders. Physical characteristics such as grain, knot, pitch and compression must be controlled when constructing wood ladders.

Specific design and construction requirements for metal ladders are minimized because of the wide variety of materials and design possibilities. However, the designs must produce ladders of enough strength and stiffness to meet the performance requirements and must not have any structural defects or hazards such as sharp edges, burrs, etc.

Reinforced plastic ladders must use fully cured, commercial-grade, thermosetting polyester resin with glass-fiber reinforcement. The environment the finished ladder will encounter (electrical hazards, temperature extremes, corrosion, outdoor weathering, etc.) should determine the material.

Test Requirements

Test requirements for the ladder materials vary. However, ladders generally are evaluated on their resistance to bending, strength in various positions, and the quality of the individual components that make up the ladder.

Usage Guidelines

Usage guidelines for portable ladders encompass selecting the proper ladder for the job being performed; inspecting before use to verify proper operation and cleanliness; evaluating ladder placement so that footing and top supports are secure and not creating a traffic hazard for pedestrians; utilizing proper climbing technique; and caring for and storing ladders properly.

Before working with a ladder, read the manufacturer's instructions. Do not use a ladder if sleepy or ill, if you are taking medication, or if there's bad weather. Do not use ladders in doorways or other high-traffic areas. If a ladder must be used near a door, make sure the door is locked and it is marked with warning signs and/or cones. If the door must be open or the ladder is in a raised position, ask a coworker to stay with the ladder to make sure an accident does not occur. Use fiberglass or wood ladders, rather than metal, near power lines or other sources of electricity to avoid electrical shock hazards. Inspect your ladder for damage before using. During your inspection, if you find it is damaged remove the defective ladder from service and identify it with a “Do Not Use” tag.

Choose the right ladder for the job. Check the label to make sure it has the proper duty rating and it is long enough for the work to be completed safely. The feet of a ladder should be level and positioned solidly on the ground. If the ground is soft or uneven, use boards under the legs for support. Test the ladder to verify that it is secure. For stability, both sides of the ladder need to be against the wall or other support. The legs on a stepladder should be spread fully and locked into position. Portable ladders must be placed at an angle, so they are one foot from the wall for every four feet of working ladder height.

Make sure hands, shoes and ladder rungs are dry. Use a second person to hold the bottom of the ladder and prevent others from disturbing it. Keep a three-point grip on the ladder (two hands and one foot or one hand and two feet) when climbing. Avoid distractions that make you turn away from the front of the ladder. Climb slowly with weight centered between side rails. Do not lean back, and never stand on the top two rungs of a stepladder or top four rungs of an extension ladder.

The Centers for Disease Control and Prevention / National Institute for Occupational Safety and Health (NIOSH) has developed a Ladder Safety App for mobile devices that features a multimodal indicator and a graphic-oriented guide for ladder selection, inspection, positioning, accessorizing and safe use. The app is available in Spanish and can be downloaded for both iOS and Android users.

Marking Requirements

Ladders must be marked with ladder size, type and/or duty rating, maximum working length (if extension ladder), highest standing level, total length of sections (if extension ladder), model number or name, manufacturer's or distributor’s name, manufacturer's plant location (if multiple plants may be coded), month and year of manufacture, and ANSI compliance and warranty (if applicable). Usage guidelines and other warning statements must also be placed on the ladders in specific locations depending on ladder type.

Commonly Asked Questions

Question: How should I handle objects safely while on a ladder?

Answer: According to the U.S. Bureau of Labor Statistics, 50% of all ladder related accidents were due to individuals carrying items as they climbed. Keeping tools in a tool belt will keep them handy and free up your hands for climbing. The use of accessories such as tool lanyards to keep tools tethered to the worker can prevent them from falling while working on a ladder. Any heavy or bulky items should be brought up only after you have reached the top. Signs or barricades can be used to warn others that work is proceeding above them, and that they should be aware of possible falling objects.

The information contained in this article is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This article is not a substitute for review of current applicable government regulations, industry standards, or other standards specific to your business and/or activities and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.

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