Each year, ladder safety makes it near the top of the most cited type of OSHA violations, so it gets a lot of attention. The OSHA regulations are located in 29CFR.1926.1050, which is also Subpart X. This covers stairways and ladders. Since violations related to ladders always show near the top of OSHA’s 10 worst offenders list every year, the safety director of every employer of ladder-using workers should take the time to become familiar with Subpart X.
Subpart X Appendix A lists five types of ladders and the ANSI standard for each:
- Manufactured portable wooden ladders.
- Manufactured portable metal ladders.
- Manufactured fixed ladders.
- Job-made ladders.
- Plastic ladders.
Your first step in ensuring your ladders are safe to use is to confirm they complied with the relevant ANSI standard at the time of purchase (or if job-made, at the time made). For purchased ladders, you can find proof of compliance in a sticker on the ladder itself, in the literature that comes with it, or on the manufacturer’s site. If there’s no such proof, you’ll need to either request it from the manufacturer or inspect the ladder in question against your copy of the relevant ANSI standard.
Your second step in ensuring your ladders are safe to use is to ensure they still comply with the relevant ANSI standard. To do this with purchased ladders, you don’t need a copy of the standard. For those, each user merely needs to inspect the ladder for serviceability before and after use. The how, why, and when of this inspection should be part of your training and procedures. The training and procedures should also cover ladder suitability (people choose the right ladder and accessories for the job).
A job-made ladder is a temporary ladder that is constructed on site to meet a specific need. It’s usually made of wood and is usually fixed in place.
What’s not covered in that list of five are fixed in place ladders. You’ll find the requirements for these and all other types of ladders in Subpart X. Essentially, they need to be sturdy enough for the loads imposed on them and they must be constructed so as to conform to specific dimension requirements. They are either bolted or welded into place.
A problem with bolted-on ladders is there’s a lot of vibration in plants (and generally other places where these are used). Often, there are thermal expansion and contraction too, so the bolts can come loose. A common fix for this would seem to be tightening the bolts. This is incorrect, however, because the locking device (e.g., split ring washer) is a single-use item. You must replace that locking device with a new one. Typically, you do not have to apply a specific torque value; you merely need to compress the new locking device. One option to prevent a recurrence is to apply a thread-locking compound on the bolt before tightening. This can, however, make it impossible to take the assembly apart again with a wrench or socket. You may need to grind the bolt off to replace it. So this option should be used only when the bolt just doesn’t seem to hold for very long.
A problem with welded-on ladders is a good weld is hard to make even under ideal conditions, and the conditions under which someone is required to weld a ladder in place are often far from ideal. A weak weld will eventually break, leaving the ladder unstable at best and dangerous at worst. In many cases, however, bolting simply isn’t an option. The solution is to ensure the welder tests the welds and repairs any that fail.
It might seem like a good idea to put fixed ladders onto a PM schedule complete with their own asset number, but it’s not a good idea. First of all, the failure rate of properly bolted or properly welded ladders is extremely low. Rather than try to devise a reasonable inspection interval for a PM, use the same rule as for any other ladder. The user inspects it before and after use. This inspection takes little time. The user only needs to give the ladder a firm shake and glance at the bolts or welds for obvious signs of defect. Assuming the ladder was properly constructed (e.g., rungs to rails), the safety issue is the mounting. In which case any defects will be obvious. Construction defects should have been identified before mounting was attempted.
It does not take much effort to ensure your ladders are safe. To make that happen, train users on the how and why of inspecting their ladders before and after use regardless of the type and regardless of whether it is fixed or portable. Doing these inspections will not only ensure each user has a safe ladder, it will also put the user’s mind on safety while using that ladder.
