If you open 29CFR 1926 and turn to Subpart X, you will see the fifth subpart is 1926.1060. This provides the training requirements for stairways and ladders.
“Wait,” you might say. “My grandson is four years old, and he has no problem using the stairs. But OSHA requires me to train my trade school graduates regarding stairs?”
Keep in mind: Your grandson is niether running welding cables or portable cords on stairways, nor does he deal with the various stairway issues raised in 1926.1052.
OSHA does, however, take this general line of thought into account. Notice the last two words in this requirement:
“The employer shall provide a training program for each employee using ladders and stairways, as necessary” [1926.1060(a)]. This means that the same employer who may get cited for failing to provide stairway and ladder training to its construction crews won’t get cited for failing to provide the same training to the administrative employees back at the home office.
Nor does the training have to be at the same level as, for example, studying for a Master Electrician Licensing exam. OSHA wants two results from the training:
- The employees can recognize hazards related to ladders and stairways.
- The employees know the procedures for minimizing those hazards.
But of course, the devil is in the details. Some details are provided in 1926.1060(a)(1). For the others, you go back to the Subpart X requirements that precede 1926.1060 and pick out the ones for which training appears to be appropriate. You can just apply common sense here, but err on the side of ensuring safety.
It’s always important to remember that the real harm of being cited by OSHA is that the citation is proof you failed your employees. Avoid that by being reasonably thorough. There’s a tiny cost to being reasonably thorough. For example, time yourself on how long it takes to say this sentence: “Use ladders only on stable and level surfaces unless you can secure them against unwanted movement.” You might have half a dozen of these nuggets of ladder wisdom you could cover in about a minute in a training session.
Follow up by restating one nugget here or there on various correspondence, making it an item in a safety talk, or even tucking a note into a drawing package for a job that is done on a ladder. You could consider a daily safety tip text message if you’re not already doing that, and make sure ladder safety statements are included in the rotation. For the communication to train (rather than annoy) your employees, stick to one idea per message, and keep it short.
This idea of reinforcing the training brings us to OSHA’s requirement for retraining [1926.1060(b)]. This is also “as necessary.” If you can make a formal session unnecessary via a continual effort at reinforcement, you would not only satisfy OSHA’s retraining requirement but you would also be sending the message that safety is so important your management talks about it in specific terms on a regular basis. Just don’t bombard people with so much they tune it out. It may turn out that this effort doesn’t make a formal session unnecessary (are supervisors seeing infractions?). Turning the volume up on messaging won’t solve that problem, you’re going to have to schedule formal training.
Appendix A is the only Appendix to Subpart X. It’s a guideline for complying with ladder load and strength requirements. It lists five ANSI standards that you could consult. If all of your ladders are portable ladders that you purchase from your electrical distributor, hardware store, or home center, you can skip this Appendix. What you do is buy the contractor-grade version of a given size/type of ladder. Yes, it’s going to cost more than one that is consumer grade. But it’s made better, will last longer, and can carry more load. It also tends to be more stable due to wider rails and other design enhancements. Look also for ladder accessories such as feet and braces to go with these ladders. Contractor -rade ladders also have higher load limits than consumer-grade ladders, but they still have limits. Ensure they are not exceeded.
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.