If you open 29CFR 1926 and turn to Subpart X, you will see the second subpart is 1926.1051. This provides the general requirements for stairways and ladders. It lists two main ones, with the first one having four subrequirements. We’ll come back to it in a moment.
The second main requirement is that employers shall provide and install all stairway and ladder fall protection systems required by Subpart X — plus comply with all other pertinent requirements — before employees begin the work that requires the use of stairways and ladders and their respective fall protection systems [29CFR 1926.1051(b)]. One of the implications is the employer can’t tell the employees to rig up something temporary for expediency’s sake. Whatever is used must be OSHA-compliant, specifically with Subpart X.
The first requirement is that the employer must provide a stairway or ladder at all personnel points where there is a break in elevation of 19 in. or more [29CFR 1926.1051(a)]. This isn’t much; it’s an inch more than a foot and a half. It’s about knee height for a man of average height. This requirement is waived if a ramp, runway, sloped embankment, or personnel hoist is provided.
What about those four subrequirements? The first one applies to spiral staircases; while important, it’s outside the scope of this discussion about ladder citation prevention. Here are the other three:
- If ladders are the only means of ingress to or egress from a working area for 25 or more employees, or when a ladder must serve simultaneous two-way traffic, the employer must provide a double-cleated ladder or at least two separate ladders [29CFR 1926.1051(a)(2)].
- When a building or structure has only one point of access between levels, that point of access must be kept clear to permit free passage of employees. What if work must be performed or equipment must be used such that free passage is restricted? In that case, provide a second point of access, and keep it clear [29CFR 1926.1051(a)(3)].
- When a building or structure has more than one point of access between levels, at least one of them must be kept clear to permit free passage of employees [29CFR 1926.1051(a)(4)].
Now, read through those again. Especially the middle one. Do you see how easy it is to “earn” a citation from OSHA? The good news is that with some basic housekeeping, it’s also easy to avoid such a citation.
About the Author
Mark Lamendola
Mark is an expert in maintenance management, having racked up an impressive track record during his time working in the field. He also has extensive knowledge of, and practical expertise with, the National Electrical Code (NEC). Through his consulting business, he provides articles and training materials on electrical topics, specializing in making difficult subjects easy to understand and focusing on the practical aspects of electrical work.
Prior to starting his own business, Mark served as the Technical Editor on EC&M for six years, worked three years in nuclear maintenance, six years as a contract project engineer/project manager, three years as a systems engineer, and three years in plant maintenance management.
Mark earned an AAS degree from Rock Valley College, a BSEET from Columbia Pacific University, and an MBA from Lake Erie College. He’s also completed several related certifications over the years and even was formerly licensed as a Master Electrician. He is a Senior Member of the IEEE and past Chairman of the Kansas City Chapters of both the IEEE and the IEEE Computer Society. Mark also served as the program director for, a board member of, and webmaster of, the Midwest Chapter of the 7x24 Exchange. He has also held memberships with the following organizations: NETA, NFPA, International Association of Webmasters, and Institute of Certified Professional Managers.