Construction work is inherently dangerous, and OSHA’s construction standards are complicated and comprehensive. Some of the standards, frankly, are pretty technical. You are required to train your employees in all of the standards applicable to your trade, but getting a multilingual, transient workforce, consisting in large part of young, risk-taking males, to understand and comply with all of the rules is no small challenge.
Since your paramount goal, however, is minimizing harm, rather than achieving 100% compliance and never being cited by OSHA, it’s a good strategy to look at the work you do pretty much every day, and to emphasize those safety issues that are easy to understand, and likely to cause serious injuries if the rules are not consistently complied with.
Falls, we all know, are the #1 hazard in construction, and a lot of falls are from ladders. Just as it’s shocking, or ought to be, to see workers wearing harnesses, but not tied off, while working 90 feet above grade, it ought to shock you into taking corrective action when you see, for example, an employee up on a visibly defective ladder, or ascending a ladder using both hands to carry a heavy load, or placing a portable ladder on a wet, slippery surface.
Ladder design is somewhat technical, but safety in the usage of ladders is not. Much of it comes down to matters of common sense. In short, it’s an aspect of your safety program that is relatively easy to get right. Accordingly, and as inattention to ladder safety is likely to result in lots of injuries as well as OSHA violations, a lack of effort in inexcusable.
OSHA regulations require training, and retraining, in all of the following:
One rule that should never be violated is that portable or fixed ladders with structural defects (e.g., broken or missing rungs, cleats or steps, broken or split rails, corroded components, etc.) should be tagged “Do Not Use,” and removed from service until repaired and restored to their original design criteria. Ladders must be inspected by a “competent person” for visible defects, periodically and after any incident that could affect their safe use.
Ladders must be kept free of oil, grease, and other slipping hazards, used only for the purpose for which designed, and not loaded beyond the maximum for which they were built, or the manufacturer’s rated capacity. Wooden ladders must not be coated with any opaque covering, except identification or warning labels, on one face only of a side rail. The rungs and steps or portable metal ladders must be corrugated, knurled, dimpled, coated with skid-resistant material, or treated to minimize slipping. Ladder components must be surfaced to prevent injury from punctures or lacerations, and prevent snagging of clothing.
Ladders must be used only on stable and level surfaces, unless secured to prevent accidental movement. They should not be used on slippery surfaces, unless or secured or provided with slip-resistant feet. Slip-resistant feet should not be used as a substitute for care in placing, lashing, or holding a ladder on a slippery surface.
The area around the top and bottom of a ladder must be kept clear. If used where the ladder or the user could come into contact with exposed, energized electrical equipment, the ladder must have non-conductive siderails.
Ladders placed in passageways, doorways, or driveways, or where they can be displaced by workplace activities or by traffic, must be appropriately secured or barricaded.
When portable ladders are used for access to an upper landing surface, the side rails must extend at least 3 feet above the upper landing surface. When such an extension is not possible, the ladder must be secured, and a grasping device, such as a grab rail, must be provided to assist users in mounting and dismounting the ladder. A ladder extension must not deflect under a load that would cause the ladder to slip off its support.
The top of a non-self-supporting (or leaning) ladder must be placed with two rails supported equally, unless it is equipped with a single support attachment. Single-rail ladders must not be used.
Non-self-supporting ladders must be used at an angle where the horizontal distance from the top support to the foot of the ladder is approximately one-fourth of the working length of the ladder. Wooden, job-made ladders, with spliced side rails, must be used at an angle where the horizontal distance is one-eighth the working length of the ladder. Fixed ladders must be used at a pitch no greater than 90 degrees from the horizontal, measured from the back side of the ladder.
Ladders must not be moved, shifted, or extended while in use. Ladders must not be tied or fastened together to provide longer sections, unless they are specifically designed for such use.
When moving up or down the ladder, the user must face the ladder, avoid leaning over laterally beyond the side rails, and use at least one hand to grasp the ladder. The user must not carry anything that could cause him to lose his balance and fall.
A metal spreader or locking device must be provided on each stepladder, to hold the front and back sections in an open position while the ladder is being used. Cross-bracing on the rear section of stepladders must not be used for climbing, unless the ladders are designed and provided with steps for climbing on both front and rear sections. The top or top step of a stepladder must not be used as a step.
Approximately one-fourth of all nonfatal falls on construction sites are from ladders. Older workers, especially, are likelier to suffer death or serious injuries in falls involving ladders.
A more comprehensive resource for construction safety professionals and onsite supervisory personnel is Carol Epling, “Preventing Falls from Ladders in Construction: A Guide to Training Site Supervisors,” which can be downloaded online from the website of the Electronic Library of Construction Occupational Safety & Health (ELCOSH).