You approach the top of the fixed ladder, ready to begin your descent. The wind howls past your ears, making you uneasy, even a bit unsteady. Frantically, you reach out to grab the hand-hold and step to the top rung before you lose your nerve.
How did you approach the top of a fixed ladder and step onto it without any hinderance whatsoever? No gate, no offset, no chain. Unfortunately, there are many locations in places of business throughout the country (and, I’m sure, the world) where ladderways simply go unprotected. These locations where people begin their descents and finish their ascents multiple times per day, where people must mount and dismount ladders dozens of feet in the air, where one misstep can take you from solid footing to no footing at all in the blink of an eye, remain unprotected day after day just waiting for an accident to occur.
Yet, these potential accidents, like most accidents, are completely preventable with a little forethought. In the case of ladderways, traditional means of protection have been simple, inexpensive solutions like gates or chains. Taking a moment to assess your workplace was usually enough to realize that protection was needed and providing it usually did not have to break the bank. However, last year, with its release of the new Walking-Working Surface standard for General Industry, OSHA reversed a decades-old decision that allowed the use of chains when protecting ladderways.
Why? Frankly, they didn’t really do the job. Chains are easy to fall over. Chains with S-hooks could easily become dislodged. Chains that workers forgot to hook back up could cause a trip hazard that would send a worker tumbling over the edge of a platform or a roof. Plastic chains were installed, which could easily break or would deteriorate after lengthy exposure to the sun’s UV rays. Chains required action by the user while either standing atop the ladder or at the edge of the roof/platform. The reasons were countless enough to wonder why OSHA had ever felt chains were a good enough solution in the first place. To be fair, the Letter of Interpretation that basically gave approval for chains stated that the chains must be at least as effective as the swinging gate, but this, most likely, was ignored in most cases because how do you determine that, exactly?
So, in 2017, OSHA’s Standard Letter of Interpretation, dated February 12 1982, which deemed the use of a chain for top and mid rails a de minimis violation (no monetary penalty and no requirement for abatement), was nullified. No more chains.
What, then, if not chains, does the new standard allow? With little to no room for interpretation, it allows for two things: a gate or an offset. That’s it. Both are still pretty easy solutions and not terribly costly, though also not as cheap as a chain may have been.
A gate is simple enough. Have a rail that meets all of OSHA’s requirements for a rail (in both height and strength) and attach a self-closing gate. The gate must swing away from the ladder so that nobody on the ladder has to maneuver around it when it opens and so that nobody on the roof or platform can accidentally walk, fall, or back through it into the ladderway. Since the gates are required to be self-closing, there is no action required by the user. With chains, the user had to stop, either at the top of the ladder or at the edge of the roof/platform, to re-hook the chain. This, of course, was counter to the whole purpose of having some type of protection in the first place.
Offsets, on the other hand, provide no physical barrier at all at the point of mounting or dismounting of the ladder, yet still provide satisfactory protection per OSHA. The idea of the offset is that you cannot back or walk into the ladderway accidentally because it’s not a straight line. You would need to make a conscious decision to enter the offset and move over to the ladderway.
If you have a facility with fixed ladders, it is important that you assess each and every one. Don’t forget that there are new fall protection device requirements that are currently being phased in because of the new Walking-Working Surface standard for General Industry as well, but at least begin by ensuring that your ladderways are protected. If you check your ladderways and see a chain, or no protection at all, disallow the use of that ladder until a solution can be implemented.
While no solution is perfect, OSHA feels that these two provide the protection necessary to keep workers safe. By mandating the use of gates or offsets, OSHA has removed as much human error as possible. Whether carrying materials, pulling/pushing equipment, or simply being distracted in the age of the smart-phone, good solutions are needed to keep workers safe from themselves.