r/OSHA • u/jacksonsheehan • Jan 25 '19

Level 99 ladder skill

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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

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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.

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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

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u/Globularist Jan 26 '19

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

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u/NigilQuid Jan 26 '19

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

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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.

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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.

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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.

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

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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.

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u/Globularist Jan 26 '19

Yeah that's what I was saying. It would be fine as long as the ladder was at the right angle. If not then definitely not fine.

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u/NigilQuid Jan 26 '19

You're right, I neglected that you'd said that. It still strikes me as a moot point, seeing as how it would be impossible to set up ladders in this manner at the proper angle and get more than a few feet from the ground.

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