Fall and slip hazards are the cause of many industrial injuries. But as I like to say: it is not a reality until it is your reality…
About a month ago, a local friend of mine was working in his yard off of an extension ladder and accidentally fell from it. He was immediately paralyzed and rushed to the hospital, where he has been there since. He has been on a feeding tube and getting physical therapy and can now barely move his limbs. He has now been sent to a specialty hospital in Minnesota, where he will be for at least two months. He may never recover from this accident. So we can all imagine his reality is real to him, his wife and family, and us his friends.
Going from the ground floor up to the roof of industrial facilities, fixed and portable ladders, and fall hazards resulting from them can exist at any change of levels. We will address only Fixed Ladders today.
The Occupational Safety and Health Administration (OSHA) Standard 1910 Subpart D – Walking-Working Surfaces addresses Ladders’ hazards. A link for its table of contents is provided as follows.
Under OSHA 1910.23, Fixed Ladders are specifically addressed in 1910.23(d)
In all of the industries we work in, such as Pulp and Paper, Food, Building Products, Chemical, and Power industries, we have observed Ladder Hazards that are in violation of 1910.23.
Some highlights of the regulations aimed at reducing some of these typical hazards include:
1910.23(d)(2)
The minimum perpendicular distance from the centerline of the steps or rungs, or grab bars, or both, to the nearest permanent object in the back of the ladder is 7 inches (18 cm);
1910.23(d)(4)
The side rails of through or sidestep ladders extend at least 42 inches (1.1 m) above the top of the access level or landing platform served by the ladder.
1910.23(d)(5)
For through ladders, the steps or rungs are omitted from the extensions, and the side rails are flared to provide not less than 24 inches (61cm) and not more than 30 inches (76 cm) of clearance. When a ladder safety system is provided, the maximum clearance between side rails of the extension must not exceed 36 inches (91 cm);
1910.23(d)(6)
For side-step ladders, the side rails, rungs, and steps must be continuous in the extension;
1910.23(d)(12)
The step-across distance from the centerline of the rungs or steps is:
1910.23(d)(12)(i)
For through ladders, not less than 7 inches (18 cm) and not more than 12 inches (30 cm) to the nearest edge of the structure, building, or equipment accessed from the ladders;
1910.23(d)(13)(ii)
A minimum perpendicular distance of 30 inches (76 cm) from the centerline of the steps or rungs to the nearest object on the climbing side. When unavoidable obstructions are encountered, the minimum clearance at the obstruction may be reduced to 24 inches (61 cm), provided deflector plates are installed;
Since November of 2018, there have been some changes to the caged ladder requirements from before as follows. They are worth greatly noting.
Note to paragraph (d): Section 1910.28 establishes the employer’s duty to provide fall protection for employees on fixed ladders, and § 1910.29 specifies the criteria for fall protection systems for fixed ladders.
1910.28(b)(9)(i)
For fixed ladders that extend more than 24 feet (7.3 m) above a lower level, the employer must ensure:
1910.28(b)(9)(i)(A)
Existing fixed ladders. Each fixed ladder installed before November 19, 2018 is equipped with a personal fall arrest system, ladder safety system, cage, or well;
1910.28(b)(9)(i)(B)
New fixed ladders. Each fixed ladder installed on and after November 19, 2018, is equipped with a personal fall arrest system or a ladder safety system;
1910.29(b)(13)
When guardrail systems are used around holes that serve as points of access (such as ladderways), the guardrail system opening:
1910.29(b)(13)(i)
Has a self-closing gate that slides or swings away from the hole, and is equipped with a top rail and midrail or equivalent intermediate member that meets the requirements in paragraph (b) of this section;
This last item is a great example of low-hanging fruit that can be easily fixed.
We specify and recommend Kee Safety Self Closing Safety Gates for all top of ladder openings onto a floor level or rest landing. They are economical and easy to install. Here is the link to their site.
In addition, there are some other great immediate safety improvements that plants can easily and economically do for their fixed ladders. These include installation of Grip Tight or Strut type of Safety Rungs or other products over the existing smooth round bar rungs to prevent slippage on them. Below are the links for some of these products:
https://www.mcnichols.com/ladder-rungs
https://www.safeguard-technology.com/anti-slip-products/ladder-rung-covers/
In closing, a few years ago, we designed some improvements to a small portion of an extensive array of process lines equipment access platforms in a fairly new food processing plant. The project fabricator had design/built these platforms. Being a food plant, with cleanliness and food safety being a high priority, the platforms were all fabricated in stainless steel with a No. 8 Mirror Finish. In addition, the ladders’ vertical side rails and rungs were all made with the same 1 ½” diameter pipe as the handrails. Further, as it was a food plant, the surfaces were oily and the ladders were not fabricated to meet OSHA regulations. The ladder rungs and side rails were too large and were slippery making them unsafe. It seemed to be such a shame that such an expensive installation did not meet code and created numerous possibilities for accidents.
Please take the time to look at your plant’s Fixed Ladder installations. If you find them to be questionable regarding OSHA code compliance or considered hazardous, please find ways to improve them.
If you need our help in conducting an audit of your plant’s Fixed Ladders or formulating a solution for their non-compliance, please let us know if we can help you. Pearl Engineering specializes in the Structural Engineering of Fall Protection Systems and works with Manufacturers and Contractors in their specification and installation, including being the Licensed Professional Engineer for them.
If you would also like us to come to do a presentation for your plant on Fixed Ladders, we would be glad to do that.
