Request Clarification of OSHA Fixed Ladders Regulations 2

[Texas Piper]

I'd like some clarification on the Fixed Ladders regulations posted by OSHA. They seem to contradict themselves in certain areas. I hope I placed this in the correct forum, it seemed the appropriate place, if not, apologies.

My concern is related to the maximum climb on a fixed ladder, when landings must be provided, when the ladders must alternate and if fall protection must be provided.

As an example:

I have a multi-level structural platform system. Elevations are: Grade, Platform at +17', Platform at +34'.

Can I have a single fixed ladder go from grade to the first platform and then the second? Ladder would be caged and then the "landing" would be the platform itself with a safety gate. Does OSHA treat this fixed ladder as a length of 34'? Or is it "two" 17' ladders because there is a "landing" in between? Is the correct way to handle this to have separate fixed ladders of 17' length each?

As I understand it the only requirement for these lengths is a cage system, they are not required to have a fall arresting system?

Thank you in advance for the advice.

 

[SwinnyGG]

Cages are not permissible as a means of fall protection for new fixed ladders erected on or after November 19, 2018, as a personal fall arrest or a ladder safety system must be installed in accordance with 1910.28(b)(9)(i)(B).

But - this requirement starts at 24'. Your first fixed ladder up to 17' would not require a fall arrest system; the second ladder run from 17' to 34' does require a fall arrest system to be compliant.

 

[Texas Piper]

Thanks for the reply SwinnyGG.

 

[JStephen]

Three or four years ago, OSHA updated all the rules, so the rules that were valid for 20 or 30 years prior were changed for new construction. So you may find conflicting information on the topic due to that.
Go to the OSHA website, look under rules and regulations, general industry if that's what you're in, look for "ladders" and "duty to have fall protection", etc.
In the case above, with two separate ladders, the lower wouldn't need anything, the upper would require the fall arrest. Might as well put it on both of them.
If it's one long ladder, it would require the fall arrest.

 

[STrctPono]

SwinnyGG nailed it! Cages are no longer compliant. Sometimes I find OSHA's "Standard Interpretations" webpage to help answer questions that seem ambiguous.

Link

I also have a recent potable watertank job where we are specifying a personal fall protection device that complies with OSHA standards. I'm not attempting to promote a particular product but something like this would work.

Link

 

[Texas Piper]

Thank you JStephen and STrctPono for your replies as well.

It had been some time since I had to conceptualize a platform layout and I got a comment about the length of the ladder and was not aware of the new rules.

In the link provided by STrctPono, OSHA clarifies that even if a ladder is less than 24', if its installed height is more than 24' from grade than an arresting system or safety system must be provided. Interesting.

Thank you again for your responses.

 

[JLNJ]

If you have a large platform at the 17’ level which precludes one from falling from the ladder up to the second level directly to the ground, you might be able to make a case that the upper ladder doesn’t need fall protection. I don’t believe OSHA gives any guidance as to the dimensions needed on the mid height platform for this to apply.

 

[JoelTXCive]

I am about to design a similar setup.

What dimensions are you thinking for your landing?

Attached is a photo of one that I saw on my way home from work. They have fall arrest on both ladders.

I like the setup with the hole in the platform, but feel they need an additional diagonal brace for some redundancy.

 

[Texas Piper]

@JLNJ

I read through some Standard Interpretations and it seems that they no longer give exemptions for ladders that are intended to be used as emergency egress only (which mine are).

This seems a little silly because in an emergency situation plant personnel aren’t going to take the time to harness up and clip into the fall arrestor.

@JoelTXCive

I’m not sure what the final arrangement will be now. I think now it makes more sense to have the ladders outside the platforms with individual landings at each platform (similar to your picture, just not on a building).

Ultimately the final design and engineering will be done by a structural firm. Our firm is conceptualizing the platform layout for our scope which is the mechanical design/engineering.

Thanks for the replies.

 

[JStephen]

On the ladder picture above, I would say there's a good chance the fall protection was added later, as it looks like the sole purpose of the platform was to make it where they didn't need the fall protection.

 

[JoelTXCive]

JStephen - You might right. I have other questions about the sample photo I took. (which are also questions Texas Piper might have)

1) The upper ladder has what I call a 'Step Over' to get up on the roof. A user will have to unhook from the fall restraint to get up and over the roof edge. I'm not crazy about this, but I don't know an alternative way you could set up?

2) The OSHA guidelines also require gates when you have ladders going down. I don't know how you would be able to do this without making the platform significantly larger (which was why I was asking about the size). Also manipulating a gate in that confined area with an opening nearby seems unsafe too.

OSHA 1910.23(a)(2)
Every ladderway floor opening or platform shall be guarded by a standard railing with standard toeboard on all exposed sides (except at entrance to opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening.

 

[Settingsun]

The top ladder might have a telescoping system that's been stowed. Alternatively there are systems with the line off to the side that goes to the top of the stile.

The gates are self closing so you just push through from the ladder. Inconvenient but not as much as falling through the floor.

As JStephen said, maybe the platform is no longer required and a ladder would go straight to the top, avoiding the gate requirement.

 

[SwinnyGG]

With the new requirements what they are, to me it makes no sense at all to have landings unless you need them for intermediate access or work to be performed at a certain level. If you have to run fall protection on the whole length of the ladder, it's a lot simpler and more cost effective to minimize or completely eliminate the landings, if you can.

If you have a large platform at the 17’ level which precludes one from falling from the ladder up to the second level directly to the ground, you might be able to make a case that the upper ladder doesn’t need fall protection.

It's not specifically laid out in the code anywhere; but there is a standard interpretation out there that seem to indicate that there is no platform size which would eliminate the protection requirement of the upper ladder.

OSHA bases the requirement on how far it is possible for a worker to fall - how likely (or unlikely) they are to miss a landing on the way down does not seem to be a factor in any way.

 

[canwesteng]

Kind of ridiculous, since a cage + a landing makes sure you can only fall on the landing.

 

[JStephen]

Normally, the climbing rail would stick up past the top rung, and you have to step around the side- which requires the ladder to be flared at that point also.

 

[Texas Piper]

Of interest is this Standard Interpretation:

https://www.osha.gov/laws-regs/standardinterpretations/2019-10-18

"if the size of a rest platform is such that a worker climbing the fixed ladder could fall past the platform and more than 24 feet to the ground or a lower level, the employer must equip the ladder with a personal fall arrest system or a ladder safety system. In the example you provided, where the rest platform measures 3 feet by 3 feet, it is possible that a worker climbing the fixed ladder could fall past the platform and to a lower level. Thus, the distance the ladder is considered to extend above a lower level would be measured from the ground and not from the lower rest platform."

So if the ladder is less than 24' and its not possible to fall beyond the lower platform, it seems that a fall arrestor is not needed.

Clear as mud?

 

[JStephen]

JoelTXCive- see this interpretation which addresses the second question you had.

https://www.osha.gov/laws-regs/standardinterpretations/1975-06-12-0

Note that his is "old", so it may or may not still apply.
But it seems the intent is that where you can walk around on a surface, you oughtn't be able to accidentally walk off due to ladder gap. But on intermediate platforms, they're not used for walking around, just for going up and down the ladder, so that is not applicable.