Some of the most common questions on ladders involve fall protection, documenting inspections, manufacturer labels, and whether OSHA would approve certain ladders. The regulations don’t answer most of these issues, but employers can address them by following best practices.
OSHA does not “approve” ladder designs, but 1910.23 does list specifications for things like the width of rungs, the spacing between the rungs, and (on fixed ladders) the space required behind the rung to a wall or object. Even though OSHA doesn’t approve ladders, the agency could issue a citation for a ladder that does not comply with the regulations.
Employers that build or install their own ladders, whether portable or fixed, should review the dimension requirements and ensure that any site-built ladders meet those specifications.
Fall protection is not required when using portable ladders but might be required on fixed ladders. The regulation on the duty to have fall protection at 1910.28 specifically says that it does not apply to portable ladders. However, that section does require a fall protection or ladder safety system on fixed ladders that reach more than 24 feet above a lower level.
Fixed ladders under 24 feet do not require fall protection. Many fixed ladders have cages, since an older regulation required a cage or well on ladders over 20 feet. Those can serve as fall protection on ladders over 24 feet until the ladder is upgraded with a fall protection or ladder safety system.
Finally, if the upper entry point to any fixed ladder is four feet or more above a lower level, OSHA requires a self-closing gate or offset. Any unprotected edge needs a guardrail or other fall protection, and a ladder entry point creates also needs fall protection.
Although OSHA requires inspecting a ladder before the first use on each shift, the agency does not require documenting those inspections. Employers can certainly provide a checklist or reminder of items to check, and some employers require creating an inspection record similar to a pre-use forklift inspection.
Since OSHA doesn’t require documentation, employers cannot get cited for missing inspection documents. However, an OSHA inspector may ask workers what items they check, or ask the employee to walk through the ladder inspection process. If the employee doesn’t know what to check or cannot identify a defect, OSHA could issue a citation. The regulation at 1910.30 requires employers to provide training on “the proper care, inspection, storage, and use of equipment” such as ladders.
Many ladder manufacturers affix labels that provide warnings, weight limits, or other information. Over time, these labels may peel off or become too worn to read, raising questions of whether OSHA requires a replacement.
OSHA doesn’t require manufacturers to place labels on ladders and doesn’t have a regulation that requires labels. Typically, manufacturers include labels to help protect themselves from liability. However, those stickers or labels usually contains safety information (like weight limits) that employees may need when selecting an appropriate ladder. As a best practice, if a sticker is missing or unreadable, employers should contact the ladder manufacturer for a replacement.
Keep in mind that labels are not a substitute for training. Although ladders seem easy to use, thousands of injuries occur each year from improper use.
The answers to compliance questions aren’t always clear in the regulations, but OSHA has issued a lot of interpretations, frequently asked questions, and other guidance to provide clarity. In addition to regulatory assistance, our experts can often help you find guidance from the many pages of published information. Submit your question through the Expert Help feature in the J. J. Keller® SAFETY MANAGEMENT SUITE and our experts typically respond in a few hours, and no more than one business day.