If you open 29CFR 1926 and turn to Subpart X, you will see it starts with 1926.1050. This provides the scope, application, and definitions that apply to stairways and ladders.
If your employees are using stairs and/or ladders in the course of construction, alteration, and/or repair, you need to understand and correctly apply 1926.1050 [1926.1050(a)]. This subpart does not cover ladders used with scaffolds; for those, see Subpart L.
The definitions start with 1926.1050(b). There are fewer than two dozen. It’s important to understand these before moving on to the rest of Subpart X because what you get here is not some affirmation of what you assume OSHA means when using one of these terms — but rather, what OSHA does mean when using one of these terms. If you perfectly implement what you thought OSHA meant (but that’s not what they actually meant), then you have opened your company to an OSHA citation for failing to implement what OSHA required.
The first word on the list is an example of this. What’s a ladder cleat? We know what football cleats and golf cleats are, so OSHA obviously means a shoe or foot for the ladder. Right? Yet when we read the definition OSHA provides, that is not at all what they mean. A cleat is “a ladder crosspiece of rectangular cross-section placed on edge upon which a person may step when ascending or descending a ladder.”
Okay, so what’s a double cleat ladder? Obviously, one with two cleats. Right? Not exactly. It’s “a ladder similar in construction a single-cleat ladder but with a center rail to allow simultaneous two-way traffic for employees ascending or descending.”
What do you think “failure” means, when it comes to OSHA’s ladder regulations? It means “load refusal, breakage, or separation of component parts.” OSHA also defines load refusal. From OSHA’s definition of failure, you can see that a missing rivet on a ladder support bracket is a failure. That rivet is a component part, and it got separated from the ladder. Any time a ladder registers a failure, take it out of service or you set your company up for an OSHA citation.
If the maximum intended load, as noted on the ladder itself, is 240 lb and John weighs 225 lb, is there an OSHA-citable violation? Maybe not if John’s tools and materials have a combined weight of no more than 15 extra lb — and there are no other loads or forces applied to any part of the ladder. The ladder has no way of differentiating between the various loads imposed on it, so what matters is (as OSHA’s definition states) “the total load of all employees, equipment, tools, materials, transmitted loads, and other loads anticipated to be applied to a ladder component at any one time.”
Becoming familiar with fewer than two dozen definitions doesn’t take much time. You might read through this list every Thursday after lunch for a month for a total investment of under an hour. That is much less time than it takes to plan and implement a policy that doesn’t meet the regulations and then have to deal with the OSHA citation (or worse, a ladder use lost-time injury). It is a much more efficient use of your time to be able to plan and implement a correct policy because you invested an hour to understand what OSHA wants you to do.
