How’s Your Ladder Safety Program?
Falls from ladders account for about 20,000 injuries and 300 deaths in the U.S. each year. However ladders in good condition and used properly are seldom a cause of an accident. The American Ladder Institute has declared March, National Ladder Safety Month.
Section 3276 of the Cal/OSHA General Industry Safety Orders and Section 1675 of the Construction Safety Orders (CSO) relate to the use of all portable ladders. Cal/OSHA as of 2011 consolidated the requirements for portable ladders into just one section, Section 3276. During visits to construction job sites, The Cohen Group commonly finds a few of the Cal/OSHA requirements being overlooked. The most commonly cited subsections of the ladder safety regulation by Cal/OSHA are:
1) Not securing a portable ladder or having it extended 3 feet above the upper landing before workers use it to reach an upper level;
2) Not providing a training program for workers on the proper construction, inspection, maintenance, care, use, and limitations of stairways and ladders; and
3) Not marking or tagging a defective ladder so that it would not be used before it has been repaired.
Cal/OSHA Section 3276, requires that before an employee uses a ladder, the employee and the employee’s supervisor be provided training in the safe use of ladders. The training must include the following topics:
1) Importance of using ladders safely
2) Injuries related to falls from ladders
3) Proper selection
4) Maintenance and inspection
5) Erecting ladders (support, securing and angle of inclination)
6) Climbing and working on ladders
7) Factors contributing to falls
This training is often not conducted or there is no documentation to show it has been conducted.
One common problem is not using the right style of ladder. For example, a worker should use an extension ladder; not an A-frame ladder closed and leaning against a wall for climbing to the roof. Another poor practice we often see is a worker using an open A-frame ladder using the top step (“top cap” or rung) to access an elevated area. A secured extension ladder which extends 3 feet above the landing should be used. Most workers are aware that these practices are unsafe and prohibited, but the employer cannot demonstrate to Cal/OSHA the workers have received training.
Another major requirement in the regulation which is often overlooked is that ladders be inspected by a “qualified” person “frequently” and after any occurrence that could affect their safe use. A ladder properly used and in good condition is a safe tool. If a ladder is dented, bent or cracked or split, or if the ladder’s feet are not in good condition, the ladder may not hold the weight for which it was designed. Though frequency is not defined in the standard, the employer should designate a time frame (e.g., weekly) and document the inspections. Note that the original language in the proposed regulation was that the inspections be done prior to the “start of the work shift”. This gives some indication as to what the Cal/OSH Standards Board was considering when the changes were originally proposed. We suggest that inspections be based on the frequency of use, how the ladder is used or handled and the environment in which it is used.
A “Qualified Person” is defined by Cal/OHSA as a person designated by the employer who by reason of his training and experience has demonstrated his ability to safely perform his duties and, where required, is properly licensed in accordance with federal, state, or local laws and regulations. Any worker who demonstrates competency (i.e., “qualified”) with the safe use of ladders can conduct the inspection.
The National Institute for Occupational Safety and Health (NIOSH) has introduced a new Ladder Safety smart phone application (app). The app provides feedback to the user on positioning the extension ladder at the optimal angle. It also provides references and a safety guide for extension ladder and step ladder selection, inspection, accessorizing, and use. This new app uses visual and audio signals to make it easier for workers using extension ladders to check the angle the ladder is positioned, as well as access useful tips for using extension ladders safely. The app is available for free download for both iPhone and Android devices. Please give The Cohen Group a call if you are looking to improve your ladder safety program.