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Standard Number: | 1926.1053; 1926.500(b) |
April 27, 2015
Jennifer Coon
7740 West New York Street
Indianapolis, Indiana 46214
Dear Ms. Coon:
Thank you for your letter to the Occupational Safety and Health Administration (OSHA), Directorate of Construction. This is in response to your letter, dated October 13, 2014. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any question not delineated in your original correspondence.
We have paraphrased your question as follows:
Scenario: When abrasive blast cleaning and painting, the inner surfaces of a water storage tank are accessed by personnel using a ladder boom. The ladder boom is constructed of a ladder attached to a lug near the floor of the tank with a system of pulleys and cables which adjust to rise and lower the height and pitch of the ladder. These ladder booms are constructed on site without the approval from the ladder manufacturer or certified by a safety professional.
Question 1: You asked if the proposed support system described above, and as pictured in the photos you submitted, would comply with OSHA standards.
Answer: No. While OSHA does not have a specific standard covering personal ladder boom support systems, the use of the equipment in the manner described would not be compliant with multiple OSHA standards. Such standards would include, but are not limited to, the OSHA construction ladder standard (29 CFR Part 1926, Subpart X), the fall protection standard (29 CFR Part 1926, Subpart M), and the scaffold standard (29 CFR1926, Subpart L). Specific standards applicable to use of this support system would include:
Please note that the use of a personal fall arrest system in conjunction with this ladder support system would not abate the hazards addressed by the standards noted above.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements, but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.
Sincerely,
James G. Maddux, Director
Directorate of Construction