Citations for ladder safety violations were No. 3 on OSHA’s list of most cited for 2024, 2023, 2022, and 2021, having risen from No. 5 in 2020 and No. 6 in 2019.
OSHA’s ladder safety requirements are in 1926.1053, which is part of Subpart X Stairways and Ladders. This is important to note because Subpart X contains:
- 1926.1050. This applies to both stairways and ladders. It provides the scope, application, and definitions.
- 1926.1051. This also applies to both stairways and ladders. It provides the general requirements.
- 1926.1052. This provides the requirements for stairways.
- 1926.1053. This provides the requirements for ladders.
- 1926.1054. This provides the training requirements for the hazards addressed in Subpart X.
- Subpart X Appendix A. This is a non-mandatory guideline to assist employers in complying with the ladder loading and strength requirements of 1926.1053(a)(1).
One mistake some safety administrators make in regard to their ladder safety program is they zero in on 1926.53 without considering the rest of Subpart X. If your only concern is ladder safety, then you should apply all of Subpart X except for the stairway requirements of 1926.52.
To get started on eliminating ladder safety violations that lead to OSHA citations, follow these five steps:
- Assess your current ladder inventory. Do you have ladders of sufficient height for the work to be done? Are the ladders electrically safe? Are they industrial grade and in good condition?
- Conduct a basic ladder safety training session that covers such items as properly angling an extension ladder and not using the top step of a step ladder.
- Conduct a ladder maintenance session that covers items, such as how to inspect a ladder before using it, how to clean it before and after use, and how to take defective ladders out of service.
- Thoroughly study all of Subpart X, including the stairway information. You want to include that because it will help you conceptually with the ladder requirements.
- Obtain your current ladder safety program and look for key things that are wrong or missing based on what you just studied. Fill in the gaps. If you do not have a current ladder safety program, as a stop gap meaure make a list of five to ten ladder safety rules and get that list out to the workers.
Getting started this way will set the tone for developing a citation-proof ladder safety policy. It needs to evolve from a process. That is the best way to get it accepted and be part of the way things are done. It is also the fastest way to improve your ladder company’s safety because you can immediately fix known problems rather than wait until somebody has written their opus and it has gone through sixteen review and approval cycles — and if you’re starting off by fixing the company’s ladder inventory problems, you are sending a clear message to the troops that the company is serious about ladder safety.
