FAQ Topics / Ladders

We have fixed ladders at our coal fired boiler plant on the coal silos,
Chimneystack and bag houses. They meet the OSHA standard-Fixed

Ladders(1910.27)-well cages installed and platforms. However to improve fall

safety we are considering adding a permanent cable or rail system. The fixed

ladders are staggered so one
of two things will be necessary. 1)-using a curved rail system so that the

climber does not have to disengage or; 2)- install shorter vertical lengths

that will require the climber to
disengage while on the platform to move over to the next staggered fixed

ladder. I have an interesting question that may very well may be posed to me;

the validity for an additional ladder safety device. Statistically is there a

high fall risk factor for climbers on fixed ladders especially ladders of

moderate height (>than 30′)?

Look for ANSI A14.3 – 2008. This standard requires vertical thrust to be addressed with drop tests as before. However the committee believes that horizontal thrust is critically important regarding the ability of the climbing device to lock or stay locked as the body falls away using a harness. No suitable test has been developed in Europe or North America and the committee will publish an addendum if a credible test protocol is received from the manufacturers.

I am seeking advice on Ladder Safety. Workers are installing overhead door motors at 18 feet, and doing high work at other random locations using ladders.

All of the ladders used are inspected daily, and are set up at better than the 4-to-1 ratio. Tools are transported up the ladders using tool belts.
No one can stand higher than 4 rungs from the ladder top. No
one “stretches” past the ladder’s sides. The workers are experienced and have received annual training.

At a recent daily Pre-Work (“Tailgate”) discussion, the following question arose from a worker: “When I climb the ladder, I use two hands to hold on to the ladder sides. But, when I’m working at height, my hands are
not on the ladder at all. What gives?”

In other words, the worker is asking, other than natural balance, what may be used to prevent falls while working at height from a ladder? The
supervisors here have discussed lanyard equipment, tie-offs, and
the like, but none seems workable. Limited floor space precludes alternatives, such
as of scissor lifts, bucket trucks, scaffolds, or similar. Ladders are the only useable tools.

What advice can you provide so our workers can be and feel more safe while working on ladders?

Portable Ladders with rungs are intended for climbing access only using three point control and no possible dismounting unless three rungs are equally spaced above the step-off point and the ladder is tied securely to prevent tipping or sliding; falling down a sloped ladder can be a bumpy ride perhaps somewhat better than on a vertical ladder but not to be recommended. Stepladders with flat steps offer more stability for
standing and working providing the worker is not pushing/pulling;
especially perpendicularly to the open frame. Stepladders offer some
increased balance postures from the rung above against the shin. They are not well suited for dismounting. A common (mis)use of stepladders is to lean the closed frame against a surface and dismount over the top step supposedly because the stepladder is not stable and has no leveling
Back to standard ladders; there are plants in the USA that require that over four feet off the ground the use of personal fall protection. The compatible anchorage must be in place and several hook designs exist for
reaching up above the work location for securing a SRL. When either a ladder or stepladder is used within its usable length range from a guardrail, the danger increases and a SRL becomes key protection. The trend for more safety is preferred because methods are practical and help provide a back-up system when the user’s hands are not available for three point control.
A system for measurement of frequency of access should be
introduced so that fall hazard exposures from ladders and stepladders can be categorized and either work platforms can be designed and installed, the work location can be lowered to standing height access or
a small aerial lift such as Snorkel’s smallest lift can become justified.

Can handrails be eliminated if a JLG Manlift is used along with a safety harness and 5 Ft. lanyard while working on top of flat containers?

You have not defined the Bodycote application of flat container and how often it occurs and if the containers are different each time.

However, generally the answer is yes for applications where it would not serve to have permanent guardrails. There is an OSHA Standard, 01-01.013, from many years ago that directs that if the visits to a piece of equipment such as a press are more frequent than once every two weeks for a total of 2 man-hours, that guardrails are required under 1910.23. However, if less than that time, fall arrest systems may be used. The standard 1910.23 does not apply to vehicles such as rolling stock, however, in a separate opinion(s) although the 5(a)(1) citation can be applied.

Q. part 1:
The question has been asked of me if we are required to install safety gates on intermediate platforms on a tank we are building on our project.
The tank is approximately 90 feet tall. There is a fixed ladder that goes up the outside of the tank about 35 feet to an intermediate platform. The platform then goes around the tank horizontally to another fixed
ladder that leads to the tank top. On the top of the tank there is a swinging safety gate that closes at the top of the ladder to have the guardrail enclose 100%of the tank top. Are we required to install one at the point where the first fixed ladder meets the intermediate platform?

Q. part 2:
Ok, so it sounds like we will need to install something. Can you
provide me with the standard that requires this so I can take this to
our engineers?

A. part 1:
If there is more than 10 feet and a ladder goes onto a platform it must have a barricade to keep someone from stepping back into space where the ladder goes down. It can be a little as a chain but there has to be something.
If you are using a basket cage on the ladder, 1910.27(d)(2) says you need a landing platform for each 30 feet (not 35′). If you’re not using a cage, there is a special exception for tanks if you are using a ladder safety device which says a landing platform isn’t required – see
1910.27(d)(5). As far as your original question, 1910.27(a)(2) gives the guarding requirement for ladderway floor openings and platforms.

A.part 2:
Check A14.3-2002 requires a gravity or spring gate for the dismount platform. This should include the rest platform for 150+ ft climbs in the 2007 revision nearly complete. Your tank ladder deserves such a barrier I believe and this should go onto design drawings for all new and existing tanks.

Chains are not effective because they typically droop and move such that
you can lose your balance pivoting over the top – one additional link is sufficient for this to occur and even if of correct length, the vertical pin design must capture the end link.

The psychological issue is that the chain is hanging vertically for 99% of the time because there is no hazard if no-one is there – and workers figure that is the way to leave it in observations I have made and discussed. Other cases, the chain sometimes pops off the pin with a horizontal push because the link twists and lifts over the pin. Bad result.

As a result of the gate, ladder climbing systems must be augmented with an anchorage point to attach lanyards before detaching the sliding device to step through the gate (unless an SRLis being used with a sufficiently high anchorage point). Check the upcoming 2007 A14.3 standard from www.ali.org.

Note: Some tank building ladders and platforms under construction have
different rules in 1926.450 Sub L App A – in all cases the issue of
residual fall hazards must be considered and remember OSHA rules are minimum as are ANSI standards due to consensus. Leading organizations commit to best practice.

Does anybody know about the type of certifications a welder must posess in order to install/construct fixed ladders? We have welders that install fixed
ladders and they were actually wanting to know about it because their insurance company is requiring them to either pursue it or prove that they are certified to do so. I know that it must meet the AWSD but is there a stamp of
approval like a UL stamp/sticker that must accompany the installation to show that the welder is certified?

ANSI A14.3 is the backbone of the federal OSHA 1910.27 regs. The new 2007 standard will be ready in a few weeks – watch www.ali.org or www.ansi.org for release date.

Bear in mind that the ladder standards do not provide an optimum level of safety like I pointed out in my comments to you previously. Getting a certified welder for this work is only the tip of the iceberg for management due diligence.
The A14.3 2002 refers to AWS D1.1 – 2002 for steel and AWS D1.2 – 1997 for aluminum.
The owner must ensure that the supplier of the fixed ladder has employed certified welders. One thing the A14.3 standard does not discuss is impact forces on torungs when ladder safety systems are tested in vertical drops. I believe this calls for rungs inserted through the siderail and welded from both sides. Also a recent presentation at the
National Safety Congress (Whitty and Simms) indicated that impact of 500 lbs/18 inches may not be supported by 3/4 inch dia. solid steel rungs.

I need to discuss if you have any ladders up to 12 ft that have safety features for my client with an orthopedic injury.

Ladders are not good for limited flexibility and restricted motion. Safety features include 1A type ladder for more stability, spreader bars and leg adjustments. The horizontal grab bars you have seen on our site are improvements for people without impediments that enable holding if a fall occurs.

Suggest a small aerial lift if the client must ascend, and leave ladders and stepladders behind.

Is there a fundamental difference in ladder safety on land vs. maritime? I know that OSHA doesn’t have authority over navigable waterways, so who would and would the usage be altered because of the difference in environment?

All vehicles including ships have places where they are stopped and load or unload at terminals. At such times they are subject to OSHA regulations. The landmark Supreme Court decision in 2002 Mallard Bay Drilling gives OSHA the right to pursue its goal of protecting America’s workers notwithstanding 4b1 of the OSHA Act of 1970 as amended when an existing agency has not provided for that safety process through investigation and regulation. Such was the case with an Uninspected Vessel fatality and the US CoastGuard. Google: Mallard Bay Drilling Supreme Court for a brief.

Having said that, there are no OSHA standards for ladders on ships other than general industry. There is also the Marine Terminals and Longshoring standards to review.

Pick a specific problem with a maritime ladder application and a particular hazard or incident to discuss further please regarding possible remedies. Differences could be hoar frost in northern waters, crew language and training, engine room access, egress from the bridge, tank ship’s ladders etc.

I am in the process of preparing a guide for inspecting various equipment.

I try to reference the regulatory requirements when I develop these documents and I am having a problem finding one. I want to specify the equipment must be inspected by the user prior to use, and by a competent person upon receipt and annually.

These have always been my requirements. When I started looking for reference, the prior to use is in 1910.66 app C and in 1926.502(d)(21).

Interesting is that I cannot find anything in OSHA that states the annual competent person inspections. I only find this in manufacturer’s instruction manuals.

I think equipment manufacturer recommendations are crucial and the only guide you have in face of evaluation of your own applications and how extreme they are relative to those instructions and warranties. Regulations and standards assume performance of machines is like new (e.g. they are maintained to perfection). In fall protection safety applications, fibreglass ladders have a real problem if exposed to sunlight for a number of years eg on the top of a pick-up truck rack, they will splinter. Perhaps plastics generally should be covered if exposed outdoors and not used. Nylon parts and webbings have a problem around weak hydrochloric acid (masonry cleaners) because their strength can diminish greatly without showing it for many months so you cannot tell without destructive testing. Nylon webbings of harnesses will stiffen if left outdoors which makes them unattractive to wear (e.g. at a truck/trailer tarping station). Ladders with hollow rungs may be acceptable in portable ladders for detailed inspection but fixed ladders 100 ft tall having hollow rungs or side rails may be impossible to inspect interior surfaces. Manufacturers of fall equipment warn of sharp edge hazards yet do not define a sharp edge because it turns out that every edge the line touches is sharp under dynamic conditions (eg falling over an edge) enough to cut the material immediately or by abrasion. An independent check or outside audit will help every couple of years to give “fresh eyes” from a qualified inspector.
Keep tuned to incidents and accident analysis about cranes, vehicles, snaphooks with damaged gates (now req. 3600 lbs) and scaffold ladders for example. Ask competitors about the weaknesses of a product; you need to know!

I just have a quick question or two concerning the “Sellstrom/RTC 2000 Climb-Rite” ladder safety system. We just had several installed under ACOE contract. The ladders are only 19 ft tall.

Best practice addresses fixed ladders over 10 ft even though the standards say 20 ft – possibly including the 3 ft extension above the top of a walk-through ladder.

The manufacturer (of ladder safety system) allows the device to be bolted either on center, using center “D” ring of a harness, or along the left side of the ladder and the use of a side “D” ring of a harness. What do you think?

That is fine. The USAF tested for side-mount to overcome wories and a case history of falling into the ladder and damaging teeth. The testing in Wilmington in 1980 showed that the left side mount allowed climbers to rotate away from the ladder face protecting the user’s face. This became a USAF Mil Spec for Ladders in 1980. Hopefully you can dig it up.

The manufacturer’s (of ladder safety system)installation instructions are not very detailed, but say you can mount the system on the left side of the ladder. Assuming the ladder is the normal 16 inches wide and the device is mounted as far left as possible, the device cuts the usable portion of the rung to a maximum width of around 14 ½ inches. Your thoughts?

Yes still a lot wider than FRA signal ladders. You can place the feet adequately to the right of the left side mounted rail.

Additionally, by mounting the ladder safety device on the extreme left side of the ladder, a “power grip” cannot be obtained, as the device interferes with your ability to grasp the ladder’s side rail. Your thoughts?

Review this website concerning GrabSafe products and also the University of Michigan NIOSH funded work on dynamic holding of side rails versus rungs completed in April 2008. The clear result is to only hold the rungs never the side rails because the hands will slide. And a hook grip rung hold is a power grip dynamically only when horizontal.

If you have a 16” ladder with ¾” steel rungs installed in 1936 with a cage around it and you modify it by cutting off the cage and installing a new fall protection device does the ladder now fall under NEW osha regs?, is it still grandfathered in?

I understand that the National Safety Council determined that ¾” rungs will not pass the 500#, 18” drop test (I take it IF it’s mounted on the rungs?)

Do you have to have an engineered anchor installed at the top?
When do you have to actually do the drop test?

The ladder, you say, was constructed in 1936. The dimensions are two side rails possibly 1/4″x2″ (?) with 3/4″ diameter rungs 16″ long and with a cage. The dismount is not mentioned. The cage is removed and a (new 2009?) cable or rail device is installed at the center (?), mounted to the rungs. Your question is whether the ladder is grandfathered from the A14 standard (A14 American Standard Safety Code for construction, care and use of ladders, 1935) and also the OSHA standards in 29CFR1921 and 1926 (1971).

The sole test envisaged is the 500 lbs/18″ free fall for your subject ladder which means an actual drop since you do not have an exemplar. Forces are typically 3000-3500 lbf in such a test over the bottom 15 ft.

The first standard for fixed ladders alone was A14.3-1956 which aside from the definition, incorporates one paragraph on Ladder Safety Devices, where substitution of life belts, friction brakes and sliding attachments must meet the design requirements of the ladder. The 500 lbs/18″ drop test was introduced later in 1974 for a particular model or style including mountings.

Cables are typically attached to extension posts and in turn to rungs on through ladders and a minimum of three rungs and possibly four rungs is needed for dynamic support depending on whether the rung is fully inserted into the side rail before welding or equivalent welding strength and a recent presentation by Whitty and Simms at a national safety conference was critical of adequate upper ladder anchorage strength. Alternatively, rail carriers are attached every 4-6 ft to rungs which reduces stress on the top rungs and the reduces the need to more carefully inspect at height for rung failure. Tubular rungs were prohibited on new ladders in 2008 and which are obviously subject to internal corrosion over time which may never be inspectable. A third alternative is the use of self-retracting lanyards (ref OSHA 1926.1053 since 1991) attached to an independent anchorage above the ladder.

You have not spoken about an engineering report of the ladder including its condition and environmental weathering and documented detailed maintenance records if any.

You speak of grandfathering the ladder possibly, presumably exempting the ladder from OSHA standards and 70 years of ANSI Fixed Ladder standards development. I would approach the ladder from a hazard viewpoint regardless of age – “an inquiry into what can injure your people”.

I would encourage the policy of best practice going forward unless you are faced here with legal principles following an incident. You should review the A14.3-2008 standard. In that standard with the first introduction of harnesses in 2003, the call for a horizontal test in addition to the vertical test was required by each user due to several free falls with catastrophic consequences when the sliding mechanism does not lock adequately.

Is there a hazard using ladders?

Most ladder applications
have a hazard of falling that cannot be denied. A ladder is a method of access from one level to another.

Suppose the ladder is at 200-250 feet on the outside of a scaffold for the
replacement of a flare tip at a refinery and accessed by suspended work platform because the fixed ladder is corroded. Do we ignore the hazard or do we in the pre-planning stage agree to put the access inside the scaffold in
the form of ladders or stairs and break the climb so fall distance is

Suppose we eliminate the use of ladders altogether? We did this at an industrial bakery in North Carolina in 1990. The subcontractors howled. So we gave them a bone and limited ladder access to ten feet standing height above which aerial lifts or a scaffold was required. BLS statistics showed that a
fatality rate at 6 ft is 1% of fall deaths and 10 ft is 10% of the total.

The hierarchy of controls for access should begin with elimination of the
need for access just like fall protection so we substitute or reschedule.
Next is stairs with handrail training and scaffolds or aerial lifts depending on application. Since ladder falls are the most dangerous of fatality cause we need to limit their use. The new hierarchy of fall protection reference Dave MacCollum’s Construction Safety Engineering Principles includes additional safety factor and redundancy (Introduction to Fall
Protection 4th edition due May 2011). So portable ladders can move to 1AAA for stability and stepladders facing the work can be held by a partner if we
reach back to ladders. Fixed ladders are beginning to have some options of simple elevating work platforms ref SIA Exhibit Philadelphia 7 21 10. The
sloped ship’s ladder has some benefits including in-built railings that must be held. In fact maybe we should angle fixed ladders to gain some support
for an otherwise vertical fall like is being considered in Australia.

Preplanning allows us to consider these options so we are not trapped by traditional views and by the 29CFR1926. Ladders will certainly be around for decades to come but homeowners may become the main market and can be helped
by the withdrawal of Type III ladders.

What are guidelines, rules or practical education for working off a portable ladder (step or extension).
Note: Beyond 3-point control for climbing and descending

Stepping on a rung or step of a ladder to work is the question – what safety issues arise and how are workers trained.
Three point control does not change for climbing, descending or working.
The proper angle of the ladder and proper good condition feet placement still applies to work.
The weight limit for use still applies and the safest choice is always the heaviest duty ladder available for anyone.
For electrical or static concerns fiberglass side rails seem to be the correct choice
The stepping must not be higher than two rungs from the top and possibly lower to keep 3 point control.
The use of a drill when the ladder is placed against a tile wall and floor is 35 lbs to avoid collapse of a portable ladder.
A step ladder must be opened fully and place perpendicularly to the work.
A portable ladder must be placed against an upper surface with three feet (rungs) extension but not more than five rungs.
When the surface of dismount is 4 in 12 or greater, use the GrabSafe extension for dismount as a walk through with horizontal grab bars. This makes it safer to dismount without climbing over the ladder to keep balance. Holding onto a horizontal round bar when about to fall is critical for a safe outcome.
Keep center of gravity or belly button between the legs of the ladder at all times  no leaning!
Carrying any items in the hand is dangerous  put pads of paper in back of pants. Other items on a cord.

We have a large number of ladders on site that are constructed using two-inch angle iron for the side rails. We recently found an OSHA
interpretation that states that these are not acceptable for use as side rails per 1910.27 (b)(2) since they do not provide adequate gripping surface. The interpretation is here:

However, when we go to buy new ladders to replace some that are failing, we find that most of what is being sold is still constructed using the angle iron.

Can you take pipe of acceptable diameter, and make a slot the entire lengthof the pipe, slide it over the outstanding leg of the angle and weld in place?

No siderail of any ladder (fixed or portable) can be held successfully in case of a fall. The rule is to always hold the rungs because the hand cannot slide. Optimal rung size is 1″ diameter solid bar considering a rung may be used for attaching a fall arrester Y-lanyard snaphook. Reference: Ph.D. thesis of Justin Young, University of Michigan 2011 link found on this website
under Ellis Ladder Improvements. The reason for long-time
concern with angle iron is that that shape is most unfriendly of all common shapes for siderails and rungs. The rule is to hold round rungs horizontally through training. The dismount at the top is also to be addressed, for instance, by the product GrabSafe also found on this website under Products.
The innovation of encasing angle iron in round pipe has been used in tower leg strengthening for cell towers. It would probably have to be 2.5-3″ diameter for 2″ angle iron. However according to Young, the ability to hold that dimension either horizontally or vertically is not possible under fall conditions. There is more to discuss relating to this subject for remediation depending on usage.