Height Restrictions & Fall Protection on Portable Ladders
Ladders tend to be one of those tools that get taken for granted because they are used so often in the home. Therefore, sometimes ladder safety gets as much consideration at work as it does at home, which is to say: zero. That needs to change. In a recent CDC article, it was noted that in the first ten years of this century (2000-2009), falls from ladders made up 43% of all fatal falls. 43%. Think that number is high? It’s nothing compared to the fact that ladders were involved in 81% of all treated fall injuries in construction workers.
One thing is clear: ladder safety needs to be taken more seriously.
This needs to start with the ladder itself. If the ladder is unsafe, then nothing you do on that ladder can be done safely. Luckily, if you’ve purchased a ladder and have made no alterations to it, then chances are that it is already OSHA compliant. Notice I said “chances are”. Nothing is guaranteed. For instance, maybe a ladder manufactured in a foreign country is subpar because the manufacturer was not aware of certain requirements. Maybe a small company is more concerned with how many ladders they can churn out instead of being concerned with safety. Your best bet is to make sure you are purchasing your ladder from a reputable company. Then, inspect it. Inspect it when you get it, inspect it when you use it, inspect it if it’s been in storage for a while. Make sure that the tool you are expecting to keep you safe is always in the best working condition.
Then, use it properly. We’ve written articles before on how to properly use a ladder, so I won’t rehash it here, but if you’re not using the ladder properly, you are not using it safely. Let’s focus, though, on height. How tall can your ladder be and still be safe (let’s assume you are simply climbing and are able to maintain three points of contact with your center of gravity between the rails – in other words, you are not working from the ladder in a situation that would require fall protection)? Well, it depends on the type of ladder.
Here is the not-so-easy answer in an easy list, based on 29 CFR 1917.119 (OSHA 1926 does not specify maximum lengths for portable ladders, but instead give very specific performance requirements that all ladders, including job-built ladders, must meet):
Portable Wood Ladders:
- Stepladders – Maximum 20’
- Type I – Industrial – 3-20’
- Type II – Commercial – 3-12’
- Type III – Household – 3-6’
- Portable Rung Ladders
- Single Ladders – 30’
- Two Section Ladders – 60’
- Trestle / Extension Trestle – 20’
- Special Purpose Ladders
- Painter’s Stepladder – 12’
- Mason’s Ladder – 40’
- Trolly / Side-Rolling Ladders – 20’
Portable Metal Ladders:
- Single Ladders or Individual Sections of Ladders – 30’
- Two Section Ladders – 48’
- Greater Than Two Section Ladders – 60’
- Stepladders / Trestle Ladders (or Trestle Sections) / Platform Ladders – 20’
So, given all of that information, when does fall protection kick-in on portable ladders?
It doesn’t, if the ladder is being used properly.
Let’s be clear. First, we are talking about portable ladders. Fixed ladders are a different story and require special ladder fall protection devices to be present when the ladder is 24’ or greater in length. Second, we are discussing what is required. Certainly, there could be times where it is obvious that fall protection would be a good idea even though the regulation does not require it (like climbing a portable ladder next to the open edge of a 15-story building).
Remember that it is your responsibility to keep your workers safe and that OSHA regulations should be considered a bare minimum.