Commonly Overlooked Ladder Requirements

Section 3276 of the GISO and Section 1675 of the Construction Safety Orders (CSO) relate to the use of all portable ladders. During recent visits to job sites, I have commonly found that a few of the requirements are either being overlooked or at the very least not documented.

The standard requires that before an employee uses a ladder, the employee and the employee’s supervisor be provided training in the safe use of ladders. Based on my field visits to construction job sites, this training is often not conducted or there is no documentation to show it has been conducted. One of the common problems relates to how ladders are used.  For example portable ladders are often used to access areas elevated by leaning the ladder in a closed or partially closed position which is not allowed by the regulations. In addition I often see workers standing and working from the top cap or on the step below the top cap. Workers are typically aware that these practices are unsafe and prohibited by the standard.

Another requirement often overlooked is that ladders are to be inspected by a “qualified” person “frequently” and “after any occurrence that could affect their use”. Though “frequently” is not defined in the standard, I recommend the employer designate a time frame (e.g., weekly) and document the inspections.  I 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.  I believe that any worker who demonstrates to their competency (i.e., “qualified”) with the safe use of ladders can conduct the inspection. Commonly however, during my investigations the contractor is not able to document the inspections of ladder or describe the frequency of inspections or demonstrate that the user is qualified.  Inspections following an occurrence that could affect their use would include if the ladder falls over or if struck by another piece of equipment such as a fork lift, etc.

Look for our next newsletter for a more detailed review of portable ladder and step ladder safety requirements.