Key definitions

• Key definitions for walking-working surfaces are found in this section.

Authorized: An employee who the employer assigns to perform a specific type of duty or allows to be in a specific location or area.

Dangerous equipment: Equipment such as vats, tanks, electrical equipment, machinery, equipment or machinery with protruding parts, or other similar units that, because of their function or form, may harm an employee who falls into or onto the equipment.

Designated area: A distinct portion of a walking-working surface delineated by a warning line in which employees may perform work without additional fall protection.

Dockboard: A portable or fixed device that spans a gap or compensates for a difference in elevation between a loading platform and a transport vehicle. Dockboards include, but are not limited to, bridge plates, dock plates, and dock levelers.

Guardrail system: A barrier erected along an unprotected or exposed side, edge, or other area of a walking-working surface to prevent employees from falling to a lower level.

Ladder safety system: A system designed to eliminate or reduce the possibility of falling from a ladder. A ladder safety system usually consists of a carrier, safety sleeve, lanyard, connectors, and body harness. Cages and wells are not ladder safety systems.

Maximum intended load: The total load (weight and force) of all employees, equipment, vehicles, tools, materials, and other loads the employer reasonably anticipates to be applied to a walking-working surface at any one time.

Opening: A gap or open space in a wall, partition, vertical walking-working surface, or similar surface that is at least 30 inches (76 cm) high and at least 18 inches (46 cm) wide, through which an employee can fall to a lower level.

Personal fall arrest system: A system used to arrest an employee in a fall from a walking-working surface. It consists of a body harness, anchorage, and connector. The means of connection may include a lanyard, deceleration device, lifeline, or a suitable combination of these.

Personal fall protection system: A system (including all components) an employer uses to provide protection from falling or to safely arrest an employee’s fall if one occurs. Examples of personal fall protection systems include personal fall arrest systems, positioning systems, and travel restraint systems.

Qualified person: A person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work, or the project.

Runway: An elevated walking-working surface, such as a catwalk, a foot walk along shafting, or an elevated walkway between buildings.

Unprotected sides and edges: Any side or edge of a walking-working surface (except at entrances and other points of access) where there is no wall, guardrail system, or stair rail system to protect an employee from falling to a lower level.

Walking-working surface: Any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.

Fall protection in general industry

• Employers must protect workers from fall hazards along unprotected sides or edges.

The Walking-Working Surfaces rule requires employers to protect workers from fall hazards along unprotected sides or edges that are 4 feet or more above a lower level. It also requires fall protection in specific situations such as hoist areas, runways, areas above dangerous equipment, wall openings, repair pits, stairways, scaffolds, and slaughtering platforms. The rule sets requirements for the performance, inspection, use, and maintenance of personal fall protection systems.

The Occupational Safety and Health Administration (OSHA) defines fall protection as “any equipment, device, or system that prevents a worker from falling from an elevation or mitigates the effect of such a fall.” Employers may choose from the following fall protection options:

• Guardrail system — A barrier erected along an unprotected or exposed side, edge, or other area of a walking-working surface to prevent workers from falling to a lower level.
• Safety net system — A horizontal or semi-horizontal, cantilever-style barrier that uses a netting system to stop falling workers before they make contact with a lower level or obstruction.
• Personal fall arrest system — A system that arrests/stops a fall before the worker contacts a lower level. Such a system consists of a body harness, anchorage, and connector, and may include a lanyard, deceleration device, lifeline, or a suitable combination. OSHA prohibits the use of body belts as part of a personal fall arrest system.
• Positioning system — A system of equipment and connectors that, when used with a body harness or body belt, allows a worker to be supported on an elevated vertical surface, such as a wall or windowsill, and work with both hands free.
• Travel restraint system — A combination of an anchorage, anchorage connector, lanyard (or other means of connection), and body support to eliminate the possibility of a worker going over the unprotected edge or side of a walking-working surface. A body belt may be used in this system.
• Ladder safety system — A system attached to a fixed ladder designed to eliminate or reduce the possibility of a worker falling off the ladder. A ladder safety system usually consists of a carrier, safety sleeve, lanyard, connectors, and body harness. Cages and wells are not considered ladder safety systems.

OSHA gives employers flexibility in choosing a fall protection system. For example, OSHA does not mandate guardrails as a primary fall protection method and allows employers to choose from accepted fall protection systems they believe will work best in a particular situation.

In addition, employers may use non-conventional fall protection in certain situations, such as designated areas on low-slope roofs. OSHA aligned fall protection requirements for general industry with those for construction, easing compliance for employers that perform both types of activities. For example, the general industry scaffold standards requires that employers comply with OSHA’s construction scaffold standards.

General industry training requirements

• Employers must train employees in the proper identification of fall hazards and use of fall protection systems and equipment.
• Training must be conducted by a qualified person.
• There is no requirement to keep training records; however, it is considered a best practice to do so.

Employers must ensure that workers who use personal fall protection and work in other specified high hazard situations are trained, and retrained as necessary, about fall and equipment hazards, including fall protection systems they will use.

A qualified person must train these workers to correctly identify and minimize fall hazards; use personal fall protection systems and rope descent systems; and maintain, inspect, and store equipment or systems used for fall protection. Training must be provided in a language and vocabulary that workers understand.

Workers must be retrained when there is a change in workplace operations or equipment, or the employer believes that a worker would benefit from additional training based on a lack of knowledge or skill.

Employers must train employees who either use or are engaged in the following:

Personal fall protection systems:

• Personal fall arrest
• Travel restraint
• Positioning devices

Equipment:

• Ladders
• Ladder safety systems
• Portable guardrails
• Designated areas
• Scaffolds
• Safety net systems
• Rope descent systems

Work situations, such as:

• When employees work on an unguarded working side of a platform used in slaughtering facilities and on loading racks, loading docks, or teeming platforms.
• When employees operate motorized equipment on dockboards not equipped with fall protection.

Fall protection systems and equipment will be effective only if they are installed, inspected, used, maintained, and stored properly and safely. The Occupational Safety and Health Administration (OSHA) believes that workers need special and specific knowledge to perform these tasks correctly. For example, to ensure safety net systems protect employees in the event of a fall, employees must know, or be able to calculate, how much weight the net will hold in that particular situation.

There is no requirement to keep training records under 1910.30. However, keeping records of all safety and health training is a best practice. This serves several important purposes, including demonstrating compliance with applicable standards. Documentation can also supply an answer to one of the first questions an incident investigator will ask: “Did the employee receive adequate training to do the job?”

Inspection requirements

• Employers must inspect walking-working surfaces regularly and as necessary to identify and correct hazards in a timely manner.

The Walking-Working Surfaces rule requires that all general industry employers conduct inspections. Essentially, if an employee uses a surface to walk on, work on, or gain access to an area in the workplace, it must be inspected.

An inspection is intended to identify and correct regulatory violations, reduce hazards, and help promote good relations with workers. Being proactive about finding and fixing hazards can help demonstrate a commitment to providing a safe workplace.

The Occupational Safety and Health Administration (OSHA) requires under 1910.22(d)(1) that inspections of all walking-working surfaces be done “regularly” and “as necessary” to ensure that they are in safe condition for employee use.

The term “regular inspection” means that an employer has some type of schedule, formal or informal, for inspecting walking-working surfaces that is adequate to identify hazards. OSHA allows employers to determine when and how often these inspections are conducted. Once an employer makes this determination, inspections must be conducted according to that frequency.

In addition, employers must also conduct inspections “as necessary.” This means inspections must be done when workplace conditions, circumstances, or events occur that warrant an additional check to ensure that walking-working surfaces are safe for employees use. These inspections would not be conducted at fixed times because situations could arise at any time that put workers at risk of slips, trips, and falls. For example, a stairway would need to be inspected if a forklift operator accidentally bumped the stairway.

The key is to ensure that walking-working surfaces are inspected often enough to identify and correct hazards in a timely manner.

A qualified person must perform or supervise any correction or repair that involves the structural integrity of a walking-working surface.

Documentation is not required for inspections, but it is considered a best practice to ensure that inspections are being done at the required frequency. Documentation also:

• Serves as a record of the company’s compliance,
• Allows a company to trace the history of a hazard(s),
• Helps identify trends (i.e., leading indicators) that could result in non-compliance if not corrected, and
• Aids in post-accident investigations.

Housekeeping requirements

• Work areas must be kept clean, orderly, dry, and free from tripping hazards.
• Good housekeeping practices protect workers and contributes to a good working environment.

Several different regulations lay out the requirements for housekeeping, including 1910.22, 1910.141, and 1910.176. In some cases, the regulations specify how to perform the duties or other associated information.

In addition, particular employers have more stringent or slightly different housekeeping procedures or functions to fulfill.

Employers must:

• Keep all areas clean and orderly and in a sanitary condition.
• Utilize housekeeping practices to reduce or eliminate the risk of combustible dust explosions.
• Keep floors clean and dry.
• Where wet processes are used, maintain drainage and use false floors, platforms, mats, or other dry standing places where practicable.
• Keep floors free from protruding nails, splinters, holes, or loose boards.
• Keep aisles and passageways clear and in good repair, with no obstruction across or in aisles that could create a hazard.
• Ensure storage is secure and does not create a hazard.
• Keep storage areas free from accumulation of materials that constitute hazards from tripping, fire, explosion, or pest harborage.
• Ensure employees keep food and drinks only in designated storage areas away from toilet rooms and toxic materials.
• Exercise vegetation control when necessary.

According to the Occupational Safety and Health Administration (OSHA), all places of employment, passageways, storerooms, and service rooms must be kept clean and orderly and in a sanitary condition. This includes floors, and, in order to facilitate housekeeping operations, the workplace is to be free of hazards such as protruding nails, splinters, holes, or loose boards. In addition, storage areas must be kept free from accumulation of materials that constitute hazards from tripping, fire, explosion, or pest harborage. Finally, storage of material must not create a hazard. For example, bags, containers, and bundles stored in tiers must be stacked, blocked, interlocked and limited in height so that they are stable and secure against sliding or collapse.

A few of the benefits of good housekeeping include:

• The conservation of space, equipment, operating materials, time, and effort makes work easier for everyone;
• The protection of product, materials, and personnel results in smaller inventories, fewer accidents, less damaged merchandise, and fewer injury claims;
• Less likelihood of fires; and
• An improvement in employee morale through a clean and orderly workplace which makes it worthwhile to come to work.

A facility that is well kept will not pose hazards. Workplaces where the aisles and exits are blocked, where debris litters the floor, or where tools and equipment are simply not put away have hazards built into them. A cluttered, unkempt workplace lends itself to slips, trips, and falls.

Are posted load ratings required?

• Under revised rules from January 2017, employers no longer need to post load ratings, but may still do so as a best practice.

The pre-2016 Walking-Working Surfaces regulation did require that load limits for buildings and structures be approved by the local building official and that load plaques be placed indicating those limits. However, under revised 1910.22(d) effective in January 2017, the Occupational Safety and Health Administration (OSHA) removed that requirement, replacing it with a more performance-oriented approach. While employers must not place loads on flooring and other walking-working surfaces beyond the load limits, the rule allows employers to obtain and enforce the information for the load limits in a variety of ways. OSHA no longer requires the ratings to be posted.

OSHA does say in the preamble to the revised rule that employers can readily obtain information about the load limits from the plaques that were required under the older standard. In other words, for existing structures, employers can rely on what was required in the past. For new buildings and structures, OSHA believes that employers can obtain load limits from building plans, local codes, and third-party certification or conduct their own evaluations.

Employers may, as a best practice, post load limits on floors and similar walking-working surfaces. However, OSHA believes that if employers ensure that all structures are designed and maintained for their intended loads, and instruct workers on those limits and how to recognize potential issues, that will be sufficient.

Aisle and walkway requirements

• Aisles and walkways should be inspected regularly and kept clean and free from obstruction.

Aisles and walkways are a part of nearly every work environment. They allow workers to smoothly get from one part of a workplace to another, acting as a shield from dangerous equipment in some cases. However, if not maintained properly, aisles and walkways can be a source of slip, trip, and fall hazards, as well as struck-by hazards.

The Occupational Safety and Health Administration (OSHA) doesn’t provide many specifics for maintaining aisles and walkways. However, OSHA has provided guidance in a few key areas.

Employers must:

• Mark aisles and walkways. OSHA does not further define how this is to be accomplished.
• Keep aisles and walkways free from obstructions.
• Provide sufficient safe clearance where mechanical handling equipment is used.
• Inspect aisles and walkways on a regular basis and as necessary.
• Correct any hazardous condition before allowing workers to use the aisles or walkways.

Aisles and walkways must:

• Be evaluated for fall or falling object hazards.
• Be maintained in a clean, orderly, and sanitary condition.
• Be kept dry; if that is not feasible, take steps to protect employees including:
  • Maintaining drainage,
  • Installing false floors, and/or
  • Providing platforms and mats.
• Be maintained free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks or spills, and snow or ice.
• Be evaluated to ensure the aisles and walkways can support the maximum intended load anticipated.
• Be capable of providing safe access and egress to and from all walking-working surfaces.

Ladder requirements

• Employers must ensure all ladders used in the workplace meet OSHA safety standards
• Employees must be trained in the proper use and inspection of the ladders they use in the workplace.

Whenever possible, the Occupational Safety and Health Administration (OSHA) uses performance-based requirements in the ladder regulation at 1910.23. OSHA believes that this will allow employers to choose the equipment that best fits their needs.

The ladder regulation applies to all general industry employers that use ladders, with only two exceptions: ladders used for emergency operations (e.g., firefighting or rescue operations) and ladders that are an integral part of a machine’s design.

Employers must ensure ladder rungs, steps, and cleats heights are:

• Parallel, level, and uniformly spaced when in the position to be used.
• Spaced not less 10 inches (25 cm) and not more than 14 inches (36 cm) apart. This must be measured between the centerlines of the rungs, cleats, and steps except:
  • Elevator shafts must not be less than 6 inches (15 cm) and not more than 16.5 inches (42 cm) apart measured from the along the ladder side rails; and
  • Fixed ladders and telecommunication towers must not be more than 18 inches (46 cm) apart measured from between the centerlines of the rungs and steps.

Stepstools also have requirements. A step on a stepstool must not be less than 8 inches (20 cm) and not more than 12 inches (30 cm) apart. This also must be measured from the centerlines of the step.

Employers must also ensure ladder rungs, steps, and cleats widths are a minimum of 11.5 inches (29 cm) apart for portable ladders and 16 inches (41 cm) apart for fixed ladders. The measurements for fixed ladders must be taken before a ladder safety system is installed. OSHA allows several exceptions for these minimums, including:

• The tapered rungs of an orchard ladder that are not intended to be steps,
• The rungs and steps of a manhole entry ladder (minimum width of 9 inches (23 cm)),
• The rungs and steps on rolling ladders used in telecommunication centers (minimum width of 8 inches (20 cm)), and
• Stepstools (minimum width of 10.5 inches (26.7 cm)).

Additional general ladder requirements include:

• Coatings on wood ladders may not obscure potential structural defects.
• Metal ladders must be corrosion resistant.
• All surfaces must be free of puncture or cut hazards.
• Ladders must be used only for the purpose they were designed.

Employers must:

• Ensure ladders meet OSHA specifications.
• Ensure employees follow all ladder climbing technique requirements including:
  • Facing the ladder while climbing up and down,
  • Using at least one hand to firmly grasp the ladder at all times, and
  • Not carrying any object or load that could cause employees to lose their balance and fall.
• Train employees in ladder climbing techniques.
• Maintain ladders in a safe condition.
• Inspect ladders before the first use every shift and as necessary.
• Remove defective ladders from service.
• Upgrade all fixed ladders over 24 feet with ladder safety systems or personal fall arrest systems by 2036.
• Train employees in ladder safety systems or personal fall arrest systems.
• Train employees on the use of required personal protective equipment (e.g., harnesses, lanyards, etc.).

Stairways

• Stairways must meet OSHA requirements and must be inspected and maintained regularly.

The stairway regulation at 1910.25 establishes requirements for the design, installation, and inspection of stairways.

The rule applies to stairways in general industry including:

• Standard
• Spiral
• Ship
• Alternating tread-type stairs

The regulation does not apply to the following:

• Stairs serving floating roof tanks
• Stairs on scaffolds
• Stairs designed into machines or equipment
• Stairs on self-propelled motorized equipment

Employers must:

• Equip all stairways having at least 3 treads and at least 4 risers with stair rail systems and handrails.
• Ensure stairs have uniform riser heights and tread depths between landings.
• Provide proper landing platforms where required.
• Inspect all stairways regularly and as necessary.
• Maintain stairways in a safe condition.

Dockboards

• Dockboards are considered walking-working surfaces and must comply with OSHA’s requirements.

A dockboard is any device used to span a gap or compensate for the difference in levels between a loading platform and a transport vehicle. Some examples include bridge plates, dock plates, and dock levelers. Dockboards can be permanent or portable.

All dockboards put into service after January 17, 2017, must comply with the requirements of the Occupational Safety and Health Administration (OSHA)’s Walking-Working Surfaces rule.

Dockboards are considered walking-working surfaces and employers must evaluate them for fall hazards. If a fall hazard exists, the employer must utilize some form of fall protection.

The evaluation also helps employers determine if their dockboards can support the maximum intended load. The maximum intended load (weight and force) includes:

• All employees
• Equipment
• Vehicle
• Tools
• Materials
• Other loads reasonably anticipated

Employers must decide, based on the maximum intended load, what material should be used to construct a dockboard. For example, portable dockboards that only need to support lightweight loads moved by a hand truck could be made from aluminum. On the other hand, steel may be needed to construct a portable dockboard that will have to support the weight of a motorized pallet jack, load, and employee.

Dockboard training

OSHA considers a dockboard to be equipment and requires that employers train each employee before the initial use of a dockboard. The training must include:

• Proper placement, and
• How to secure the dockboard to prevent movement.

Portable dockboards

Each employer must evaluate their needs and choose appropriate dockboards for the work that is being done.

Portable dockboards must be secured by

• Anchoring them in place, or
• Using equipment or devices to prevent them from moving out of a safe position.

If neither of the two are feasible, OSHA requires that the dockboard make sufficient contact in the transport vehicle. OSHA considers sufficient contact to be at least 4 inches inside the transport vehicle.

Portable dockboards must also have a means for safe handling. OSHA suggests handholds or other means of gripping the dockboard. When portable dockboards will be moved mechanically, OSHA suggests the use of forklift loops, lugs, or other effective means. The employer must evaluate how to safely move the portable dockboard and prevent employee injuries.

Who must conduct the training?

• Training must be conducted by a qualified person who has a degree, certificate or professional standing, or extensive knowledge of and experience in the subject matter.

The trainer (i.e., qualified person) must have a degree, certificate, or professional standing OR extensive knowledge, training, and experience to solve or resolve problems relating to:

• The subject matter (e.g., how to use personal fall protection, designated areas, ladder safety systems, etc.),
• The work (e.g., working on a roof), or
• The project.

The Occupational Safety and Health Administration (OSHA) is clear that trainers do not have to possess a degree if they have the necessary knowledge, training, and experience to be qualified.

Also, OSHA says that a competent person is not a qualified person. OSHA believes that personnel “qualified” to train workers in all of the subjects and topics specified under 1910.30 must have the capabilities of qualified persons. These capabilities extend beyond the current definition of a competent person. A qualified person must meet a higher threshold of requirements than a competent person.

Nonetheless, OSHA believes that many employers can draw upon the knowledge and experience of their staffs to provide effective training. Crew chiefs, supervisors, operations personnel, and other individuals at a facility can train workers — provided they have the necessary degree or extensive knowledge, training, and experience. Employers may use outside personnel to train workers if, again, the trainer is a “qualified person.”

Marking and width requirements

• OSHA requires employers to mark aisles and walkways in some situations.
• Employers must evaluate their workplaces to determine an appropriate aisle width based on the specific conditions in the workplace.

The Occupational Safety and Health Administration (OSHA)’s Walking-Working Surfaces rule does not specify that aisles and walkways be marked. However, if mechanical handling equipment is used, sufficient safe clearances must be allowed for aisles and walkways and 1910.176(a) requires the employer appropriately mark permanent aisles and walkways.

Marking

OSHA does not require a specific color, as long as employers clearly define the area considered as aisle space. Employers may use lines, strips, or other methods to define the area.

Painted lines are usually the most convenient and inexpensive way to mark aisles and passageways since the lines normally last several years without maintenance or repainting. On dirt floors or floors having continuous concentrations of sand or dust, painted floor markings may not be practical. Other methods such as marking pillars, powder stripping, flags, traffic cones, barrels and many other devices are appropriate as long as recognition is included in vehicle operator and employee training programs.

Width

The width of aisles and passageways is generally not specified, other than in specific instances. Examples of these specific instances include requirements for aisles 3 feet wide inside storage rooms holding flammable and combustible liquids (1910.106) and requirements for minimum exit access widths of 28 inches (1910.36(g)(2)-(3)). While 1910.22(c) and 1910.176(a) outline general aisle requirements, they do not specify aisle widths.

However, the recommended width of permanent aisles is at least 3 feet wider than the largest equipment to be utilized. The width of the largest equipment includes the width of the widest load carried if the load is wider than the frame of the equipment. For example, if forklifts might carry 12-foot-long lumber horizontally, the aisle width should be 15 feet or more.

Employers must also comply with any applicable local or state building and fire codes.

OSHA requires at 1910.176(a) that “where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made.” In addition, that regulation says that permanent aisles and passageways must be appropriately marked. OSHA offers no further regulation on the issue. As such, employers must evaluate their workplaces to determine an appropriate aisle width based on the specific conditions in the workplace.

Inspection requirements

• Employers must conduct regular inspections of their aisles and walkways.

Inspections must be conducted regularly and as necessary. The Occupational Safety and Health Administration (OSHA) uses a performance-based approach instead of mandating inspection frequency. This allows employers some flexibility to establish a schedule of how often inspections need to be done given circumstances and variables in the workplace.

The term “regularly” means that an employer has some type of schedule, formal or informal, for inspecting the aisles and walkways that is adequate to identify hazards. Once an employer makes this determination, OSHA expects the inspections to be conducted according to that frequency.

Subpart D also requires employers to conduct inspections “as necessary.” This means that they must be done when particular workplace conditions, circumstances, or events occur that warrant an additional check of the aisles or walkways to ensure that they are safe for employees use.

Additionally, OSHA requires that if a deficiency is found that repairs must be made before employees are allowed to use the aisle or walkway.

Although not required by OSHA, many employers find checklists helpful to ensure that critical compliance requirements and other items are not overlooked.

Key definitions

• Key definitions for ladders are found in this section.

Cage: An enclosure mounted on the side rails of a fixed ladder or fastened to a structure behind the fixed ladder that is designed to surround the climbing space of the ladder. A cage also is called a “cage guard” or “basket guard.”

Carrier: The track of a ladder safety system that consists of a flexible cable or rigid rail attached to the fixed ladder or immediately adjacent to it.

Combination ladder: A portable ladder that can be used as a stepladder, extension ladder, trestle ladder, or stairway ladder. The components of a combination ladder also may be used separately as a single ladder.

Grab bar: An individual horizontal or vertical handhold installed to provide access above the height of the ladder.

Ladder safety system: A system designed to eliminate or reduce the possibility of falling from a fixed ladder. A ladder safety system usually consists of a carrier, safety sleeve, lanyard, connectors, and body harness. Cages and wells are not ladder safety systems.

Mobile ladder stand (ladder stand): 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. A mobile ladder stand also may have handrails and is designed for use by one employee at a time.

Mobile ladder stand platform: A mobile, fixed-height, self-supporting unit having one or more standing platforms that are provided with means of access or egress.

Riser: The upright (vertical) or inclined member of a stair that is located at the back of a stair tread or platform and connects close to the front edge of the next higher tread, platform, or landing.

Side-step ladder: A type of fixed ladder that requires an employee to step sideways from it in order to reach a walking-working surface, such as a landing.

Stepstool: A self-supporting, portable ladder that has flat steps and side rails. The term includes only those ladders that have a fixed height, do not have a pail shelf, and do not exceed 32 inches (81 cm) in overall height to the top cap, although side rails may extend above the top cap. A stepstool is designed so an employee can climb and stand on all of the steps and the top cap.

Through ladder: A type of fixed ladder that allows the employee to step through the side rails at the top of the ladder to reach a walking-working surface, such as a landing.

Well: A permanent, complete enclosure around a fixed ladder.

Inspection requirements

• Ladders must be inspected before each use, and defective equipment must be removed from service immediately.

The Occupational Safety and Health Administration (OSHA) requires that all ladders be inspected before the initial use every shift. Ladders must also be inspected as necessary, such as after a ladder falls over or potentially gets damaged during use. OSHA believes that the employer can determine what should be inspected for each type of ladder before the ladder is used.

OSHA recognizes that the inspection done before the first use of the shift may be different from an inspection conducted “as necessary.” For example, an inspection done before the first use may include a check that the rungs are parallel and the footing is stable, but an inspection that is conducted if a ladder is struck by a vehicle may look for structural cracks, missing rungs, or bent spreaders.

If a defect is found during use or inspection, the ladder must be immediately tagged “Dangerous: Do Not Use” or other similar language that meets the requirements of 1910.145. The ladder must also be immediately removed from service until repaired or replaced.

Training requirements

• Employers must train employees on the proper use of ladders, correct climbing techniques, and how to use any safety systems that are in place.
• Employees should be trained to recognize fall hazards in the work area.
• Training must be conducted by a qualified person.

Employers are required to:

• Train each employee how to use personal fall arrest systems and/or ladder safety systems if used on a fixed ladder.
• Train employees to recognize fall hazards in the work area.
• Provide training and information in a manner that each employee understands.
• Retrain employees when deficiencies in performance or knowledge are noted, or when there are changes in the workplace or equipment.

Note: Training must be developed and conducted by a qualified person.

The Occupational Safety and Health Administration (OSHA) clarifies proper climbing techniques in 1910.23. The climbing techniques include:

• Employees must face the ladder while climbing up and down the ladder.
• Employees must maintain a three-point contact while climbing up and down the ladder. This requires that the employee firmly grasps the ladder with one hand at all times.
• Employees must not carry anything up or down a ladder that could cause them to lose their balance and fall.

In a letter of interpretation (LOI) dated June 5, 2019, OSHA clarified that the rule requires employees to use at least one hand to grasp the ladder when climbing up and down it, but does not require employees to grasp a specific portion of the ladder, such as the horizontal rungs. The intent is for workers to maintain three points of control while climbing. OSHA considers grasping the horizontal rungs preferable, but recognizes that there may be times when it is necessary for employees to hold the side rails.

Note: OSHA states in the preamble to the Walking-Working Surfaces rule that the sliding hand technique is no longer allowed.

Portable ladders

• OSHA has additional requirements for portable ladders that cover load capacity, slipping on rungs/steps, moving while occupied, and more.

The portable ladder requirements are in addition to the requirements for all ladders. The Occupational Safety and Health Administration (OSHA) also uses performance-based requirements for portable ladders.

OSHA has several requirements for portable ladders, including:

• Rungs and steps must be treated to minimize the possibility of slipping while climbing up and down the ladder. OSHA suggests the use of skid-resistant coatings, dimpling or corrugating metal rungs and steps, etc.
• Stepladders and combination ladders must be equipped with metal spreader or locking devices.
• Ladders must not be loaded beyond their maximum intended load capacity. This includes the weight of the employee and any tools or equipment carried.
• Portable ladders must be used on stable surfaces; if the surface is slippery, the stepladder must be secured.
• Single rail ladders are not allowed.
• A portable ladder cannot be moved or shifted when an employee is on the ladder.
• A portable ladder placed in a passageway, doorway, etc., must be secured to prevent displacement, and be guarded by a temporary barricade.
• The cap or the top step of the stepladder may not be used as a step.
• The top of a non-self-supporting ladder must be supported by both rails, unless the ladder is equipped with a single support attachment.
• A portable ladder must extend at least 3 feet above an upper landing surface.
• Portable ladders and ladder sections must not be tied together, unless they are designed for such use.
• Portable ladders must not be placed on boxes, barrels, etc., to gain additional height.

Fixed ladders

• OSHA sets standards for fixed ladders that are in addition to the requirements for all ladders.

The fixed ladder requirements are in addition to the requirements for all ladders. The Occupational Safety and Health Administration (OSHA) also uses performance-based requirements for fixed ladders.

OSHA has several requirements for fixed ladders, including:

• Fixed ladders must be capable of supporting the maximum intended load.
• Employers must ensure there is a minimum of 7 inches (18 cm) perpendicular distance from the centerline of the steps and rungs or grab bars, or both to the nearest permanent object in the back of the ladder. OSHA makes one exception — elevator pit ladders only require a minimum perpendicular distance of 4.5 inches (11 cm).

OSHA focused on the requirements for fixed ladder extension areas. The goal is to allow workers to safely transfer from the fixed ladder to the landing surface. Several requirements include:

• Fixed ladder grab bars do not extend, on the climbing side, beyond the rungs; they must also extend at least 42 inches (1.1 m) above the access level and be at least the size (cross-section) as the ladder rungs.
• The side rails extend at least 42 inches (1.1 m) above the top access level or landing platform. If the access level is a roof, the 42 inches is measured from the top of the parapet or if the parapet has a pass through, the 42 inches is measured from the roof.
• If the fixed ladder is a “through ladder,” the rungs are omitted for the last 42 inches. The extensions must also flare out at a minimum of 24 inches (61 cm) and a maximum of 30 inches (76 cm). If a ladder safety system is used, the maximum clearance between the rails of the extension cannot exceed 36 inches (91 cm).
• For side-step ladders, the side rails, rungs, and steps must be continuous in the extension.

OSHA requires the following when a fixed ladder ends at a hatch cover:

• The hatch cover must open with sufficient clearance to easily get on and off the ladder, and
• That counterbalance hatch covers must open at least 70 degrees.

Note: In a letter of interpretation (LOI) from July 27, 2000, OSHA addressed a question of whether fixed ladders that terminate at a hatch must have grab bars extending above, since they may interfere with closing the hatch. OSHA noted that the American National Standards Institute (ANSI) standard A14.3-1992, Safety Requirements for Fixed Ladders, section 5.2.3.1, Extensions for Individual Rung Ladders, stipulates that the general requirement for extension of the ladder above the access/egress level does not apply to ladders “intended for manholes and terminations with hatches.” However, OSHA also noted that guardrails around the opening may be necessary. If the hinged cover is left up while workers are on the roof, the hole would need to be guarded.

Additional fixed ladder requirements include:

• Individual rung ladders must be designed so the employee’s feet cannot slip off the rungs.
• The pitch of the fixed ladder cannot be greater than 90 degrees.
• The step-across distance for:
  • A through ladder is not less than 7 inches (18 cm) and not more than 12 inches (30 cm), and
  • A side-step ladder is not less than 15 inches (38 cm) and not more than 20 inches (51 cm).

OSHA requires that fixed ladders without cages or wells have a clear width of at least 15 inches (38 cm) on each side of the ladder centerline to the nearest object (e.g., a wall) and a minimum perpendicular distance of 30 inches (76 cm) from the centerline of the steps or rungs to the nearest object on the climbing side.

Mobile ladder stands

• OSHA’s mobile ladder stand and mobile ladder stand platform requirements are in addition to requirements that apply to all ladders.
• Employers must ensure that mobile ladder stands and platforms are slip resistant and unable to tip over.

The mobile ladder stand and mobile ladder stand platform requirements are in addition to the requirements for all ladders. The Occupational Safety and Health Administration (OSHA) also uses performance-based requirements for these units.

As defined in 1910.21, mobile ladder stands and mobile ladder platforms are ladders that are mobile, have a fixed height, and are self-supporting.

A “mobile ladder stand platform” is a mobile ladder stand with treads leading to one or more platforms. One difference is that a mobile ladder stand is designed for use by one worker at a time, and a mobile ladder platform has one or more platforms and more than one worker can use the platform or platforms at the same time.

The steps and platforms must be slip resistant. Slip-resistant surfaces must be either part of the design and construction, or provided as a secondary process, such as dimpling, knurling, shotblasting, coating, spraying, or applying durable slip-resistant tape.

OSHA says that employers have both an initial and continuing obligation to ensure that steps and platforms remain slip resistant. If the slip resistance applied by the manufacturer wears down or needs repair, employers must take steps to restore the slip resistance. For example, if slip-resistant tape comes off, the employer must replace it. Problems with slip resistance may be noticed during inspections.

Mobile ladder stands and platforms that have wheels or casters must be equipped with a system to impede horizontal movement when an employee is on the stand or platform. Stands or platforms must not move (or be moved) when an employee is on the unit.

The height of a mobile ladder stand or platform must not exceed four times the shortest base dimension. If the height does exceed the shortest base dimension, additional support is required and can include:

• Outriggers,
• Counterweights, or
• Other ways that stabilize the mobile ladder stand or platform.

Employers need to determine the best way to prevent a stand or platform from tipping over.

Guarding at the top

• Entrances at the top of fixed ladders are considered holes, and fall protection standards for holes apply.
• A fixed ladder entry point must have a self-closing gate or an offset passage.

The entrance at the top of a fixed ladder is considered a ladderway “hole.” Fall protection requirements for holes are found under 1910.28(b)(3). It 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.”

Also, 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, regardless of height, must be guarded in this manner.

An offset passage may be used in lieu of a self-closing gate. The Occupational Safety and Health Administration (OSHA) does not provide a definition of “offset passage” but does say that the barrier must prevent a person from walking directly into the opening of a hole. This is usually an L-shaped guardrail so there is no direct entrance/passage to the opening at the top of the fixed ladder. Essentially, the worker would not be able to directly access the ladder opening without walking around the inside railing that is offset from the outside railing, thus affording a protective barrier.

Safety chains are not allowed as fall protection at fixed ladder entrances. OSHA believes that 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, 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 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.

Cages and wells, and platforms

• OSHA requires fixed ladders to be upgraded with personal fall arrest or ladder safety systems by 2036.
• Cages and wells can be used in combination with required safety systems, provided they do not interfere with the systems.

Cages and wells

Cages and wells were the primary fall protection on fixed ladders installed before November 19, 2018. However, on or before November 19, 2036, existing fixed ladders over 24 feet must be upgraded with personal fall arrest systems or ladder safety systems. All newly installed fixed ladders over 24 feet (those installed on and after November 19, 2018) must have one of those systems.

The Occupational Safety and Health Administration (OSHA) has said that employers may use a cage or well in combination with a personal fall arrest system or ladder safety system provided that the cage or well does not interfere with the operation of the system.

Cages and wells must be designed, constructed, and maintained:

• To permit easy access to and egress from the ladder.
• To contain employees in the event of a fall.
• To direct employees to a lower landing.

Cages and wells must:

• Have sections that are offset from adjacent sections, and
• Have landing platforms provided at maximum intervals of 50 feet.

Employers may choose to install cages or wells on fixed ladders under 24 feet, since those ladders do not require a ladder safety system or fall protection system.

Platforms

Fixed ladder platforms must be at least 24 inches by 30 inches.

Personal fall arrest systems and ladder safety systems must:

• Provide protection throughout the entire vertical distance of the fixed ladder for all ladder sections, and
• Provide a landing platform at maximum intervals of 150 feet, if the fixed ladder has one or more sections.

Ladder safety systems

• Ladder safety systems offer fall protection for workers using fixed ladders.
• OSHA defines the required specifications for ladder safety systems.

A ladder safety system is a fall protection option that is permanently attached to a fixed ladder and is immediately adjacent to the ladder. The system must be designed to eliminate or reduce the possibility of falling from a ladder. The ladder safety system is made up of two parts:

• The carrier, also called a lifeline, which is a rigid or flexible track attached to or adjacent to the fixed ladder, and
• A safety sleeve, which is a moving component that travels on the carrier.

A ladder safety system allows employees to climb up and down using both hands. It must not require the employee to continuously hold, push, or pull any part of the system while climbing.

Additional requirements include:

• The connection between the carrier/lifeline and point of attachment to the body harness or belt cannot exceed 9 inches;
• Mountings for the rigid carriers are attached at each end of the carrier, with intermediate mountings spaced, as necessary. This will provide the system the strength to stop a worker falling;
• Mountings for flexible carriers are attached at each end of the carrier and cable guides and are installed at least 25 feet apart along the entire length of the carrier;
• The design and installation of the mountings and cable guides must not reduce the design strength of the ladder; and
• The ladder safety system and any support systems must be capable of withstanding, without failure, a drop test consisting of an 18-inch drop of a 500-pound weight.