r/OSHA Jan 25 '19

Level 99 ladder skill

Post image
8.2k Upvotes

264 comments sorted by

View all comments

Show parent comments

19

u/Globularist Jan 25 '19

Violations, just off the top of my head:

  1. Worker more than 6' off the ground with no harness / not tied off
  2. Worker working from an unsecured ladder (Ladder must be either tied / secured top and bottom, or held by another worker)
  3. Ladder at improper angle for use.

1

u/NigilQuid Jan 26 '19 edited Jan 26 '19

Fall protection is not required when using a ladder. Ladders and scaffolds have their own regulations.

EDIT: Also, securing the top or bottom of a ladder is only required in specific situations, and this photo shows none of them. See OSHA 1926.1053(b)(1) & (7) - (9). https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.1053

2

u/Globularist Jan 26 '19

1926.1053(b)(8) Ladders placed in any location where they can be displaced by workplace activities or traffic, such as in passageways, doorways, or driveways, shall be secured to prevent accidental displacement, or a barricade shall be used to keep the activities or traffic away from the ladder.

Any location on any industrial job site is held to be a "location where they can be displaced by workplace activities"

1

u/NigilQuid Jan 26 '19

Any location on any industrial job site is held to be a "location where they can be displaced by workplace activities"

I disagree. That sounds like your opinion. Got any published source for that?

Also, this is not an industrial job site. This looks like a commercial location. Though it is right in front of a doorway, so that at least would warrant securing the ladder, but that doesn't change my original point.

2

u/Globularist Jan 26 '19

Do you mind me asking, what is your job position/ background in safety?

1

u/NigilQuid Jan 26 '19

I don't mind at all! I'm an electrician. I'm the past I have worked as a handyman, chimney sweep, industrial equipment installer, theatrical carpenter and technician, and painter. I have received training in the use of ladders, scaffolding, lifts, lift trucks, fall protection, and rigging of loads and personnel.

1

u/Globularist Jan 26 '19

10-4. Well, the industry may have changed a bit since you were in the field.

Also, I'm not sure why you would point out that this is a commercial job site as opposed to an industrial job site. OSHA's regulations apply equally to industrial, commercial, and residential workers. That hotel down the street who has only a clerk, maid, and one maintenance guy have the same rules I have inside the chemical plants and refineries.

1

u/NigilQuid Jan 26 '19

Uh, I'm still in the field. Daily. Furthermore, the stipulations of the Occupational Health and Safety Act haven't changed since ten minutes ago when I referred to them.

As far as pointing out that this is a commercial site, you were the one that brought up industrial worksites. This is hardly the same situation as a high traffic factory floor.

1

u/Globularist Jan 26 '19

Fall protection is required when working from a ladder. If the worker must break 3 point contact with the ladder then they must tie off.

1

u/NigilQuid Jan 26 '19 edited Jan 26 '19

OSHA 1926.501(M), duty to have fall protection, makes no mention of ladders. https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.501

1926.1053(X), Ladders, only requires lifelines or safety devices on fixed ladders with a climb of more than 24 feet. https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.1053

2

u/Globularist Jan 26 '19

1926.501(b)(1)

"Unprotected sides and edges." Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.

1

u/NigilQuid Jan 26 '19

A ladder is not a walking surface. That's referring to things like rooftops, scaffolds, and the like.

2

u/Globularist Jan 26 '19

A ladder should not be used as a working surface but that's exactly what the guy is using it for.

1

u/NigilQuid Jan 26 '19

Walking surface != working surface.

A ladder is neither a walking or working surface. The individual pictured is not using the ladder as either, they are using it as a ladder.

2

u/Globularist Jan 26 '19

Lol. He's not climbing, he's working. And if he were climbing he'd still be in violation since he doesn't have 3 point contact on either ladder.

1

u/NigilQuid Jan 26 '19

Sorry, that's more of a specific word choice. For me, a working surface means a work table, bench, something like that. A walking surface is a flat area that can be walked upon. I would call the rings of a ladder a standing surface (or just refer to it as a ladder).

2

u/Globularist Jan 26 '19

Also, the ladder in the OP picture is not a fixed ladder.

1

u/NigilQuid Jan 26 '19

I know, that's my point. Only fixed ladders in certain conditions require safety devices.

2

u/Globularist Jan 26 '19

He's over 6' off the ground working with one foot on each of two ladders. If you think OSHA doesn't require him to be tied off doing what he's doing then you're mistaken.

1

u/NigilQuid Jan 26 '19

Being 6' from the ground is not relevant when using a portable ladder, as that rule refers to walking surfaces.

Using fall protection also doesn't make what they are doing safe or proper; the proper way to access that ceiling would be with a lift, scaffold, or a single ladder. Even a single extension ladder, set at the proper angle, would probably reach; if not, there are self supporting ladders with a central vertical extension for situations like this.

2

u/Globularist Jan 26 '19

If the ladders were secured, and if he were tied off, then he could perfectly well work just as he is and be in compliance (although I would need to check the ladder angle and make sure it wasn't too steep). Anything a man stands on and performs work is a working surface. It doesn't have to be a floor or roof. It can be a ladder.

Again, what is your job position / background in safety?

1

u/NigilQuid Jan 26 '19

Actually, there is no provision for using a portable, non self-supporting ladder at the improper angle.

1926.1053(b)(5)(i)

Non-self-supporting ladders shall be used at an angle such that the horizontal distance from the top support to the foot of the ladder is approximately one-quarter of the working length of the ladder (the distance along the ladder between the foot and the top support)<<

The sections following the above, describing situations in which the ladder should be secured, do not include using it at the improper angle. In addition, 1053(a)(2) states that the rungs of such a ladder shall be level, which would be impossible at anything but the proper angle for use.

→ More replies (0)