Quick View of Ladder Safety Requirements under the new 29 CFR 1910.23

Falls from ladders account for 20 percent of all fatal and lost work-day injuries in general industry.

The new rule includes requirements to protect workers from falling off fixed and portable ladders as well as mobile ladder stands and platforms. (The ladder requirements do not apply to ladders used in emergency operations or ladders that are an integral part of or designed into a machine or piece of equipment).

Timeline - Most of the rule became effective January 17, 2017, 60 days after publication in the Federal Register, but some provisions have delayed effective dates, including:

  • Ensuring exposed workers are trained on fall hazards (May 17, 2017),
  • Ensuring workers who use equipment covered by the final rule are trained (May 17, 2017),
  • Inspecting and certifying permanent anchorages for rope descent systems (November 20, 2017),
  • Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures (November 19, 2018),
  • Ensuring existing fixed ladders over 24 feet, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system (November 19, 2018), and
  • Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet (November 18, 2036).

 

For the three areas listed below (b,c,d) the full regulatory text can be found at:

https://www.osha.gov/walking-working-surfaces/RegTextWWSFinalRule.pdf

 

In the general requirements for all ladders section (29 CFR 1910.23 (b) ), ladders must be capable of supporting their maximum intended load, while mobile ladder stands and platforms must be capable of supporting four times their maximum intended load. Each ladder must be inspected before initial use in a work shift to identify defects that could cause injury. The specific dimension parameters and safe work practices that apply to all ladders can be found starting on page 9 of this section.

Portable Ladders (29 CFR 1910.23 (c) ) – Portable ladders usually consist of side rails joined at intervals by steps, rungs, or cleats. They can be self-supporting or lean against a supporting structure. The final rule will be easier for employers and workers to understand and follow because it uses flexible performance-based language instead of detailed specification and design requirements (unless required under the general ladder requirements of 29 CFR 1910.23 (b)). Under the revisions, employers must ensure that: rungs and steps are slip resistant; portable ladders used on slippery surfaces are secured and stabilized; portable ladders are not moved, shifted, or extended while a worker is on them; top steps and caps of stepladders are not used as steps; ladders are not fastened together to provide added length unless designed for such use; and ladders are not placed on boxes,  barrels, or other unstable bases to obtain added height. See Figure D-1 on page 12 of the regulatory text for an example of a portable ladder set-up.

Fixed Ladders (29 CFR 1910.23 (d) ) – Fixed ladders are permanently attached to a structure, building, or equipment. These include individual-rung ladders, but not ship stairs, step bolts, or manhole steps. The new rule phases in a requirement for employers to have ladder safety or personal fall arrest systems for fixed ladders that extend more than 24 feet, and phases out the use of cages or wells for fall protection under the following timeline: Starting in two years, all new fixed ladders and replacement ladder/ladder sections must have a ladder safety or personal fall protection system. For existing ladders, within two years, employers must install a cage, well, ladder safety system, or personal fall arrest system on fixed ladders that do not have any fall protection. Within 20 years, all ladders extending more than 24 feet must have a ladder safety or personal fall arrest system. See Figure D-2 thru D-5 on pages 14 & 15 of the regulatory text for examples of the fixed ladder requirements of this section.

Mobile ladder stands and platforms (29 CFR 1910.23 (e) ) will be covered in a later edition of the Safety Spotlight.