Walking Tall: And climbing the ladder of success

March 1, 2004

Walking Tall
And climbing the ladder for success

By Fred Workley

The Department of Labor Occupational Safety and Health Administration (OSHA) on May 2, 2003 published a proposed rule to amplify 29 CFR Part 1910 [Docket S-029]. The title was "Walking and Working Surfaces; Personal Protective Equipment (Fall Protection Systems)." This proposed rule may be finalized later this year or in early 2005. If you did not read the original on May 2, 2003, you should read this article. The rule is going through a final economic-analysis, impact study. The final rule will be published in the Federal Register. You need to be walking tall while following the new regulation and climbing the ladder safely to ensure your success.

This OSHA rule "Walking and Working Surfaces" sets forth general industry requirements for employers to protect employees from slips, trips, and falls that may cause serious or fatal injuries. The personal protective equipment (PPE) section, contains general requirements covering the use and maintenance of PPE, as well as specific provisions on the use, design, and performance requirements for various types of PPE such as eye, face, head, and respiratory protection.

The proposed rule updates many requirements in the existing standards. For example, the proposal has added provisions allowing employers to use alternative means to protect employees from fall hazards (e.g., designated areas, personal fall protection equipment, safety nets) when guardrails and physical barriers are not feasible.

The proposal includes design and performance criteria for several types of personal fall protection systems, including lifelines, lanyards, body belts and harnesses, and work positioning device systems.

Other OSHA standards covering specific types of workplaces and equipment in general industry currently include provisions that require employers to provide personal fall protection systems, powered platforms for building maintenance, and vehicle-mounted elevated and rotating work platforms.

Mobile equipment
Rolling stock and self-propelled, motorized mobile equipment are of special concern. Employee exposure to these types of surfaces is usually brief and sporadic, such as performing periodic maintenance. There is concern that these surfaces don't contain anchorage points for fall protection equipment.

Scaffolds and controlled descent devices (CDDs) most commonly used are mobile manually propelled scaffolds and boatswains' chair.

Employers who use CDDs to perform building cleaning, inspection, and maintenance must do so in accordance with the manufacturer's instructions, warnings, and design limitations. In addition, OSHA said it expected employers using CDDs to implement eight specific safety provisions covering the following areas: employee training, inspection of equipment, proper rigging, separate fall arrest systems, installation of lines, rescue, prevention of rope damage, and stabilization with fall protection.

Surface conditions and clearances
Surfaces shall be designed, constructed, and maintained free of recognized hazards that can result in death or serious injury to employees.

The employer shall ensure through regular and periodic inspection and maintenance that walking and working surfaces are in safe condition. And then ensure that all hazardous conditions which are discovered are corrected, repaired, or temporarily guarded to prevent employee use. Repairs shall be made in a manner that will restore the walking and working surface to a safe condition for employee use.

Only qualified persons shall be permitted to inspect, maintain, or repair walking and working surfaces except for the incidental cleanup of nontoxic materials.

Employers shall ensure that all employees who use ladders with a working height of 6 feet or more receive the necessary training, such as how to inspect and use ladders properly.

Ladders shall be used only for the purposes for which they were designed.

Nonself-supporting ladders shall be used at an angle such that the horizontal distance from the top support to the foot of the ladder is approximately one-fourth of the working length of the ladder (the distance along the ladder between the foot and top support).

When ladders are used for access to an upper landing surface, the ladder siderails shall extend at least 3 feet above the upper landing surface to which the ladder is used to gain access; or, when such an extension is not possible, the ladder shall be secured at the top and a grasping device, such as a grabrail, shall be provided to assist employees in mounting and dismounting the ladder.

Ladders shall be used only on stable and level surfaces unless secured to prevent their accidental displacement. Nonself-supporting ladders shall not be used on slippery surfaces unless secured or provided with slip-resistant feet to prevent accidental displacement.

Ladders with structural or other defects shall be immediately tagged with a danger tag reading "Out of Service," "Do Not Use," or similar wording and shall be withdrawn from service until repaired.

All ladder repairs shall be made by a qualified person trained and familiar with the design and the proper procedures for repairing defective components.

Ladders shall be inspected for defects prior to use during each work-shift, and after any occurrence which could affect their safe use.

The top of a nonself-supporting ladder shall be placed with the two rails supported unless it is equipped with a single support attachment.

The top of a stepladder shall not be used as a step.

Working loads, etc.
The working loads corresponding to the duty ratings of portable ladders shall be as follows: Extra heavy duty, heavy duty, medium duty, and light duty.

The combined weight of the employee and any tools and supplies carried by the employee shall not exceed the maximum intended load of the ladder.

Ladder rungs and steps shall be uniformly spaced when the ladder is in position for use.

Wood ladders shall not be coated with any opaque covering, except for identification or warning labels which may be placed on one face only of a siderail.

Metal ladders shall be protected against corrosion.

Ladder surfaces shall be free of puncture or laceration hazards.

Fixed individual rung ladders shall be constructed to prevent the employee's feet from sliding off the end.

A ladder that might contact uninsulated energized electrical equipment shall have nonconductive siderails.

A metal spreader or locking device shall be provided on each stepladder or combination ladder when used in the stepladder mode to hold the front and back sections securely in an open position. All treads shall be identical.

Employee training shall consist of instructions in the proper placement and securing of the ramps and bridging devices, securing of vehicles, and the proper use of material-handling equipment.

Fall protection
Employers shall provide a guardrail system as the primary fall protection system. When the use of a guardrail system isn't feasible, the employer shall provide an appropriate alternative such as personal fall protection systems, hole covers, safety nets, etc., which complies with the requirements.

Scaffolds shall be inspected for visible defects prior to each day's use and after any occurrence which could affect a scaffold's structural integrity. Deficiencies shall be corrected before use.

Safety platforms include floors, ramps, roofs, and similar walking and working surfaces.

Employees exposed to unprotected sides or edges of surfaces that present a falling hazard of 4 feet or more to a lower level or floor holes shall be protected by a fall protection system.

Each employee shall be protected from falling by body belts or harnesses, lanyards, and lifelines, separate from the chair support system. Boatswains' chair tackle shall be correctly sized for the rope being used and the rope shall be "eye" spliced.

All units shall be given a visual inspection prior to use for defects that could cause employee injury. The employer shall ensure that the manufacturers' specifications for inspection and maintenance are met where applicable.

Defective units shall be tagged "Do not use" or with a similar legend and removed from service until repaired by a qualified person.

Mobile elevating work platforms
This includes all load-supporting structural elements of units that are made of nonductile materials. Unit platforms shall meet the following requirements:

The platform shall be provided with a fall protection system meeting the requirements.

All components of a hydraulic or pneumatic system, whose failure could result in free descent or an uncontrollable fall of the unit, shall have a bursting strength that exceeds the pressure attained when the system is subjected to the equivalent of four times the system's design factor. All other hydraulic components shall have a bursting strength of at least two times the design factor.

Where the platform is supporting its maximum intended load by a system of wire ropes, chains, or both, the safety factor of the wire rope or chain shall not be less than eight to one, based on the ultimate strength of the rope or chain in use.

Elevating assembly
The elevating assembly shall be equipped and maintained so that it will not allow a free descent or an uncontrollable fall in the event of the assembly's failure. Any unit equipped with a powered elevating assembly shall be supplied with a clearly marked means for emergency lowering that is accessible from the ground.

Outriggers and stabilizers shall be constructed to prevent unintentional retraction.

Tools and materials should be secured from falling or removed.

Keep walking and climbing safely to "Keep 'em Flying."

For more information visit www.osha.gov.

Fred Workley is the president of Workley Aircraft and Maintenance Inc. in Alexandria, VA, Benton City, WA, and Indianapolis, IN. He holds an A&P certificate with an Inspection Authorization, general radio telephone license, a technician plus license, ATP, FE, CFI-I, and advance and instrument ground instructor licenses.

About the Author

Fred Workley