• Employers must provide a self-closing gate or offset to keep workers from falling through ladderway holes.

The entrance at the top of a fixed ladder is considered a “hole” that must be guarded. Fall protection requirements for holes are found under 1910.28(b)(3). Paragraph (iii) requires that “each employee is protected from tripping into a ladderway floor hole or ladderway platform hole by a guardrail system and toeboards erected on all exposed sides, except at the entrance to the hole, where a self-closing gate or an offset must be used.”

Guardrail system requirements specific to holes are found in 1910.29(b)(13) which says, “when guardrail systems are used around holes that serve as points of access (such as ladderways), the guardrail system opening must have a self-closing gate...or is offset to prevent an employee from walking or falling into the hole.” All fixed ladder entrances that are four feet or more above a lower level must be guarded in this manner.

Safety chains are not allowed as fall protection at fixed ladder entrances. The Occupational Safety and Health Administration (OSHA) specifically addresses safety chains regarding fixed ladder openings in the preamble to the walking-working surfaces final rule by stating:

“... OSHA believes that chains are less protective than self-closing gates. Self-closing gates and offsets are passive fall protection methods that automatically restore guardrail protection as soon as the worker passes through the opening or offset area. Neither method requires the worker to take any action to restore that protection. However, if employers provide double chains at entrances to ladderway floor or platform holes, their employees would have to remove the chains and reattach them once they pass through the opening. If workers forget or fail to reattach the chains, they and others in the area could fall through the hole. Workers also are at increased risk of falling through the hole once they enter the area inside the guardrails to climb down the ladder because they have to turn around and away from the hole to reattach the chains and risk falling backward into the hole.”