No. OSHA specifically exempts portable ladders from fall protection under 1910.23(a)(2)(i).
The Agency further addresses this issue in a January 13, 2000 Letter of Interpretation (LOI), however. In the LOI, OSHA says that if the user is at risk of falling from a portable ladder OSHA encourages employers to provide additional fall protection.
There are a number of factors to consider in these situations, including:
- The height of the ladder,
- The type of work being performed,
- Conditions of the work environment, and
- The limitations of the fall arrest system used.
Employees should be properly trained to use a ladder as a means of fall prevention per 1910.23(11), (12), and (13).