In the preamble to this rule, OSHA explained that this exception was needed because of the exigent conditions under which emergency responders perform emergency operations and training. 23(a)(1) only applies to ladders specifically used in emergency operations such as firefighting, rescue, and tactical law enforcement operations, or training for these operations. Question 2: If the access point from the roof and ground levels to the ladder were clearly marked to indicate for emergency use, would the exception apply in this situation as it relates to installation of ladder safety system? An elevator is normally used to access the roof of the structure. The ladders described in question #1 are only in place for emergency escape from the roof level of the structure should there be an emergency and personnel are on the roof at the time of the emergency. 23(a)(1), there is an exception for ladders used in emergency operations such as firefighting, rescue, and tactical law enforcement operations, or training for these operations. Thus, the distance the ladder is considered to extend above a lower level would be measured from the ground and not from the lower rest platform.īackground: Under. ![]() In the example you provided, where the rest platform measures 3 feet by 3 feet, it is possible that a worker climbing the fixed ladder could fall past the platform and to a lower level. If the fall distance exceeds 24 feet, regardless of the length of the ladder section, the employer must equip the fixed ladder with a personal fall arrest system or a ladder safety system.įurthermore, if the size of a rest platform is such that a worker climbing the fixed ladder could fall past the platform and more than 24 feet to the ground or a lower level, the employer must equip the ladder with a personal fall arrest system or a ladder safety system. The distance a ladder section is located above the ground or a rest platform, and thus the distance that a worker climbing on the ladder could fall, determines whether a personal fall arrest system or a ladder safety system is required. 28(b)(9)(i), the employer must measure the distance from the ground/lower level to the top of the fixed ladder. For purposes of determining whether a fixed ladder extends more than 24 feet above a lower level within the meaning of. 28(b)(9)(i)(B), employers must ensure that each new fixed ladder extending more than 24 feet above a lower level is equipped with a personal fall arrest system or a ladder safety system. Question 1: Does each section of ladder above 24 feet from the ground require a ladder safety system or is the 24-foot height measured from rest platform to rest platform? Some of the ladder sections are less than 24 feet in length. The rest platforms measure 3 feet by 3 feet in area. Rest platforms will be installed at each off-set and will be provided with guardrail systems to meet OSHA’s requirements. OSHA’s responses follow your questions.īackground: Multiple sections of off-set ladders are being designed to be installed on the outside of a grain silo that is 80 feet or more in height. The background information and questions you provided in your inquiry are paraphrased below. ![]() This letter replaces our previous response to you dated April 16, 2019, which has been rescinded. Thank you for your November 7, 2018, letter to the Occupational Safety and Health Administration (OSHA), regarding fixed ladders covered under OSHA’s General Industry Walking-Working Surfaces standard.
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