Non-Slip Ladder Rung Requirement

[JLNJ]

My apologies for he re-post, but I posted this in the OSHA forum and could hear the ckickets whilst I was typing.

I was able to easily find OSHA's requirement for non-slip ladder rungs in 1926: "1926.1053(a)(6)(i) The rungs and steps of fixed metal ladders manufactured after March 15, 1991, shall be corrugated, knurled, dimpled, coated with skid-resistant material, or otherwise treated to minimize slipping..."

but I am trying to locate the similar requirement for fixed ladders covered under 1910.27.

My understanding is that, while the requirements are similar, one reg covers construction sites (1926) and one covers permanent workplace requirements (1910).

It makes sense that ALL ladder rungs be non-slip, but I can't find the actual regulation for it in 1910. Maybe it's not a requirement for fixed ladders. Or maybe I'm missing a recent rule similar to the March 15, 1991 requirement for 1926.

I did posit this to OSHA via their website, but I'm not counting on a timely response.

 

[fegenbush]

The requirement does not exist for non-slip ladder rungs in 1910.

 

[JStephen]

OSHA regulations in regards to ladders, etc., are kind of in a mess right now. About 20 years ago, they published some "proposed" regulations, but never actually enacted them, but compliance with the proposed regulations is adequate to avoid OSHA fines, etc. Those proposed regulations were then re-published a few years ago but still not enacted. And OSHA currently has a publication on their website that seems to reflect the requirements of the proposed regulations. However, the CFR's still don't reflect those changes. So don't expect logic there.

 

[Bagman2524]

I'm not aware of any requirements for non-slip ladder rungs in 1910 either. OSHA also problems/conflicting information with guard heights. They haven't updated their standards for years.

There is ample precedent in the history of science for the overwhelming bulk of the scientific community strongly believing in imaginary entities postulated by a favovered theory. -Michael Behe

 

[humanengr]

I usually use deformed rebar for the rungs regardless if non slip is reqd.

 

[JLNJ]

OSHA sent me a link to a portable ladder pamphet of guidelines (in a Do Not Reply To email):

OSHA Quick Card Portable Ladder Safety

https://www.osha.gov/Publications/portable_ladder_qc.html

Ladders must be free of any slippery material on the rungs, steps or feet.

Not much help for fixed ladder requirements. This is your Federal Government at work.

 

[JStephen]

This may be the publication you want:

https://www.osha.gov/Publications/osha3124.pdf

Note that this is a 2003 publication. However, it states:
"Rungs and steps of fixed metal ladders manufactured after March 15, 1991, must be corrugated, knurled, dimpled, coated with skid-resistant material or treated to minimize slipping."- Page 6, left hand column.

This Interpretation mentions the original publication and also the re-publication of the proposed standard, notice the link for the re-publication:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27295

. I don't see that non-skid requirement in the OSHA regulations or in the proposed regulations, either.

There on the OSHA site, if you click on the "Regulations" link, and scroll down, you'll find the "current" regulations, which don't agree with the "current" 2003 Publication 3124.

Among other amusing oddities: In the regulations, a stair railing is required to be "not more than 34 inches nor less than 30 inches from upper surface of top rail to surface of tread", 1910.23(e)(2). This has been the standard for many years, and is still shown on the OSHA website under Regulations right now. Meanwhile, in Publication 3124, "When the top edge of a stair rail system also serves as a handrail, the height of the top edge must be no more than 37 inches (94 cm) nor less than 36 inches (91.5 cm) from the upper surface of the stair rail to the surface of the tread." So do you comply with a "regulation" or with a brochure that "does not alter or determine compliance responsibilities in OSHA standards"?