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#172870 12/28/07 03:16 PM
Joined: Dec 2006
Posts: 43
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Junior Member
Hi,
I am working with a company that says OSHA says that you do not tie off while on a portable ladder.

I have never been told not to tie off while working on a ladder. especially more than 6 feet.

Please quote article if known,

Thanks

Windmiller


We all live under one King
Arc Flash PPE Clothing, LOTO & Insulated Tools
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K
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I was just looking through the book that I got at a required OSHA "Construction Safety and Health" course I took last spring.
This is by no means a complete guide to OSHA standards though.

It would seem that on any construction site, OSHA wants you to use a fall arrest protection appropriate for the type of work being performed whenever you can fall six feet or more. [29CFR 1926 Subpart M] also referenced are OSHA Publications 3124 and 3146.
I don’t know how you could always comply with this on a ladder, unless you wear a personal fall arrest system [PFAS] and can somehow tie off at the top somewhere.
This OSHA book also says to secure ladders to prevent accidental movement due to workplace activity or when the possibility for it to slip exists.

You could always do a search on OSHA's website. There's a lot of reading to be had there.


KJay #172877 12/28/07 08:26 PM
Joined: Aug 2007
Posts: 853
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Note: "FALL ARREST".

I beleive it is over 10 (ten) feet. Before fall Arrest comes into play. I'll have to check.

But I do know (after being cited),that near an opening, elev pit,stairwell etc. You must be at least as far away as the ladder is tall,or be tied off.

EX: 6' ladder- six feet away-8'-10' etc. if closer, you need to be tied off.

10' for me and a $225 fine.(contractor paid, My as- chewed)

"Sorry, Dude".

Joined: Jan 2003
Posts: 4,391
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I went to the OSHA web site and found OSHA interpretations.

In my opinion the only way to clear up OSHA rules is right from OSHA any other source is questionable including myself, that is why I recommend going to www.osha.gov yourself to verify anything anyone tells you. cool

OSHA has a good web site and you can usually find what you want to know. The actual standards are available on line and many times you can find "Standard Interpretations" which I find very helpful of clearing up certain sections.

OK, keep in mind that the rules are different for portable and fixed ladders.

This first quote applies to portable ladders.

Quote
Standard Interpretations

01/13/2000 - Fall protection requirements for fixed and portable ladders in construction.

Portable ladders: fall protection is not required for employees climbing or working on portable ladders.


Neither the ladder standard (29 CFR 1926, subpart X) nor the fall protection standard (29 CFR 1926, subpart M) requires fall protection for workers while working on portable ladders.

You note that a number of general contractors in Georgia "are attempting to require personal fall arrest systems for their subcontractors working on ladders 6 feet or higher." Although the OSHA standards do not require fall protection for workers on fixed ladders below 24 feet or on portable ladders, we encourage employers to provide additional protection.


Now for 'Fixed ladders'

Quote
Fixed ladders: fall protection must be provided for employees climbing or working on fixed ladders above 24 feet.

29 CFR 1926.1053(a)(19) states that fall protection must be provided whenever the length of climb on a fixed ladder equals or exceeds 24 feet. A fixed ladder is "a ladder that cannot be readily moved or carried because it is an integral part of a building or structure" (§1926.1050(b)). Also, even if the length of climb is less than 24 feet, under §1926.1053(a)(18), cages, wells, ladder safety devices, or self-retracting lifelines must be provided where the top of the fixed ladder is greater than 24 feet above lower levels.


You can view the whole page here

Now standard interpretations are not the actual standard, for that we can look at 1926.500(a)(2)(vii)

Quote
1926.500(a)(2)(vii)
Requirements relating to fall protection for employees working on stairways and ladders are provided in subpart X of this part.


That section means people on ladders are not subject to the rules in 1926.500 Fall Protection


Bob Badger
Construction & Maintenance Electrician
Massachusetts
Joined: Jan 2003
Posts: 4,391
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Moderator
Here is another more recent standard interpretation about this subject.

11/28/2007 - Whether OSHA requireme...ion is required. 29 CFR 1926.1053(b).



Quote
November 28, 2007

Mr. Robert S. Beisel
Safety Consultant
Project Best, Inc.
21 Armory Drive
Wheeling, WV 26003-6396

Re: Whether OSHA requirements prohibit working from a portable stepladder and, if not, whether fall protection is required. 29 CFR 1926.1053(b).

Dear Mr. Beisel:

This is in response to your letter submitted April 27, 2006 to the Occupational Safety and Health Administration (OSHA). Your inquiry addresses the use of portable stepladders and fall protection. We apologize for the long delay in responding.

We have paraphrased your question as follows:

Question (1): Does 29 CFR 1926.1053(b)(4) prohibit an employee from working from a portable stepladder?

Answer (1): Title 29 CFR 1926.1053(b), Use, provides:
* * *
(3) Ladders shall not be loaded beyond the maximum intended load for which they were built, nor beyond their manufacturer's rated capacity.
(4) Ladders shall be used only for the purpose for which they were designed.
* * *
(13) The top or top step of a stepladder shall not be used as a step.
* * *
There are no OSHA construction standards that specifically prohibit an employee from working from a portable stepladder. However, the use of a portable ladder must comply with the Use requirements quoted above. If working from a portable stepladder was inconsistent with any of these provisions, such use would be prohibited. Because of the wide variety of circumstances and ladder designs, it is not possible for us to state, as a general matter, whether working from a portable ladder would be consistent or inconsistent with any of these provisions.

Question (2): Is fall protection required while working from a portable stepladder?

Answer (2): In 29 CFR Part 1926 Subpart M (Fall protection), Section 1926.500(a)(2)(vii) provides:
Requirements relating to fall protection for employees working on stairways and ladders are provided in Subpart X . . .
* * *

There is no provision in Subpart X that requires fall protection for an employee while working from a portable stepladder. However, if the employee will be on a surface prior to ascending or upon exiting the ladder for which another Subpart in 1926 requires fall protection, then fall protection would be required at such times. General requirements for fall protection can be found at Subpart M of 29 CFR Part 1926, while requirements specific to a particular activity or equipment can be found at its applicable Subpart in 29 CFR Part 1926.

If you need any additional information, please contact us by fax at: U.S. Department of Labor, Directorate of Construction Office of Construction Standards and Guidance, (202) 693-1689. You may also contact us by mail at the above office, Room N3468, 200 Constitution Avenue N.W., Washington, D.C. 20210; although there may be a delay in our receiving correspondence by mail.

Sincerely,



Steven F. Witt,
Directorate of Construction


Bob Badger
Construction & Maintenance Electrician
Massachusetts
iwire #172902 12/29/07 03:44 PM
Joined: Jul 2007
Posts: 1,335
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Member
Thanks Bob, that was my interpretion as well but wanted to bounce it off my OSHA specialist before I mis-interpret it. YOu got to ask your self, how to you tie off on a step ladder?

Last edited by sparkyinak; 12/29/07 03:45 PM. Reason: I can't spell worth a crap

"Live Awesome!" - Kevin Carosa
iwire #173023 12/31/07 06:19 PM
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Originally Posted by iwire

In my opinion the only way to clear up OSHA rules is right from OSHA any other source is questionable


I agree Bob,
Best to get the information from the horses mouth, rather than get someone-elses interpretation of it, this can really get you in trouble.

Trumpy #173039 12/31/07 10:33 PM
Joined: Mar 2007
Posts: 165
Member
Originally Posted by Trumpy
Best to get the information from the horses mouth...

Rather than the opposite end, eh? laugh

(From another cat servant)

Joined: Jul 2007
Posts: 1,335
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With OSHA, what is the difference the same sh... er, stuff comes out of both end smile


"Live Awesome!" - Kevin Carosa
Joined: Mar 2005
Posts: 1,213
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Member
I've often wondered... how is the cage around a fixed ladder supposed to prevent a fall? Simply losing your grip or your footing will send you straight down, where there is no cage beneath you. I mean, maybe your leg would get tangled as you fall and get you tumbling head-first, but the cage really doesn't seem to be a substitute for "real" fall protection.

Not that I don't mind not having to wear a ball-buster on ladders like this, but still...

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