Falls from ladders account for about 20,000 injuries and 300 deaths in the U.S. each year.聽 The Cohen Group commonly finds a few of the Cal/OSHA requirements overlooked during our safety inspections at construction job sites.
Cal/OSHA General Industry Safety Order Portable Ladders Standard and Cal/OSHA Construction Safety Order, Article 25 Ladders both relate to the use of all portable ladders. 聽However, Cal/OSHA consolidates the requirements for portable ladders into 8 CCR 搂 3276.聽 The most commonly cited subsections of the ladder safety regulation by Cal/OSHA are as follows:
- Not securing a portable ladder or having it extended 3 feet above the upper landing before workers use it to reach an upper level.
- Not providing a training program for workers on the proper construction, inspection, maintenance, care, use, and limitations of stairways and ladders as described below.
- Not marking or tagging a defective ladder so that it will not be used before it has been repaired.
- Using a stepladder in a leaning and closed position.
Cal/OSHA Portable Ladders Standard requires that before an employee uses a ladder, the employee and the employee鈥檚 supervisor must be provided training regarding safe use of ladders which must include the following topics:
- Importance of using ladders safely
- Injuries related to falls from ladders
- Proper selection
- Maintenance and inspection
- Erecting ladders (support, securing and angle of inclination)
- Climbing and working on ladders
- Factors contributing to falls
Unfortunately, this training is often not conducted and/or there is no documentation to show it has been conducted.
One common problem is not using the right style of ladder.聽 For example, a worker should use an extension ladder; not a step ladder closed and leaning against a wall for climbing and working in elevated areas. Non-self-supporting ladders, which must lean against a wall or other support, are to be positioned at such an angle that the horizontal distance from the top support to the foot of the ladder is about 1鈦�4 the working length of the ladder. Recently, companies have redesigned their stepladders to be used safely in the closed leaning position and in compliance with the OSHA standard. Another poor practice often seen is a worker using an open step ladder while using the top step (鈥渢op cap鈥� or rung) to access an elevated area.聽 A secured extension ladder that extends 3 feet above the landing should be used. Always maintain a 3-point (two hands and a foot, or two feet and a hand) contact on the ladder when climbing. Keep the body near the middle of the step and always face the ladder while climbing. Most workers are aware that these practices are unsafe and prohibited but in haste may use the ladders incorrectly.
Another major requirement in the regulation which is often overlooked is that ladders be inspected by a 鈥渜ualified鈥� person 鈥渇requently鈥� and after any occurrence that could affect their safe use. A ladder used properly and in good condition is a safe tool.聽 If a ladder is dented, bent, cracked or split, or if the ladder鈥檚 feet are not in good condition, the ladder may not hold the weight for which it was designed.聽 Though frequency is not defined in the standard, the employer should designate a time frame (e.g., weekly) and document the inspections. We suggest that inspections be based on the frequency of use, how the ladder is used and the environment in which it is used.聽 A 鈥淨ualified Person鈥� is defined by Cal/OHSA as a person designated by the employer who by reason of his training and experience has demonstrated his ability to safely perform his duties and, where required, is properly licensed in accordance with federal, state, or local laws and regulations.聽 I believe that any worker who demonstrates to their employer competency (i.e., 鈥渜ualified鈥�) with the safe use of ladders can conduct the inspections. Commonly, however, during my investigations, the contractor is not able to document the ladder inspections or describe the frequency of inspections.
Bottom Line: Ladder accidents are preventable. The better you can prepare your workers for proper ladder use, the better you can mitigate risk and prevent ladder accidents. Ladders in good condition and used properly are seldom the cause of an accident.
Note: This information was provided by Tim Bormann, CIH, FAIHA, The Cohen Group