Do you need a ladder gate at your ladder opening in your railing? According to OSHA 1910.23(a)(2) “Every ladderway floor opening or platform shall be guarded by a standard railing with standard toeboard on all exposed sides (except at entrance to opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening.”
This means that every ladder opening needs to be either (a) Offset so that a person cannot walk (or fall) directly into the opening or (b) Protected by a ladder safety gate. It is an easy either/or. The most common ladder installation locations are not offset and as such require safety gates. Below you will see some photos of ladders and top view sketches clarifying why each of their orientations either do or do not require a gate.
One quick note – there is often a source of confusion surrounding the OSHA standards because of the passage further in the standard (1910.23(c)(1) which states “Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a toeboard wherever, beneath the open sides, persons can pass, there is moving machinery, or there is equipment with which falling materials could create a hazard.”
Many people had been incorrectly interpreting this believing that if their ladder opening was under 4’h, a gate was not required. OSHA has cleared up this misconception by stating “Unguarded ladderway floor openings and unguarded ladderway entrances on all surfaces should be cited under section 1910.23(a)(2)”, for all intents and purposes, if you have a ladder opening, it is required to meet OSHA 1910.23(a)(2).
Now that we know what the code requirement is, it is time to review a few common ladder mounting orientations to discuss where they fall under the code.
The above fixed ladder is mounted onto the side of the platform. Work is performed further down the platform but it is possible to fall directly down the ladder opening. This location is not offset and as such would require a swing gate. See the below top view sketch for clarification.
You can walk directly to the ladder opening from where work is/can be expected to be performed and as such, a safety gate is required at the ladder opening.
The above ladder accesses a platform and then turns to access the main walkway. This ladder is offset and would not require a swing gate at the opening.
As you can see above, if someone fell while at the main walkway they would fall onto the ladder landing surface, they would not fall down the ladder opening. If the ladder was rotated to the left side of the landing it would require a safety gate because then the ladder opening would no longer be offset.
Above is a very common ladder mount position. This one can be tricky until you lay it out from the top view. From first glance it looks like because the ladder is off to the side that it would be offset from the normal flow of traffic, but if you fell at that point of the catwalk there would be no guarding to protect you. A swing gate is a requirement at this location.
As you can see from the above sketch, there is a single direction of travel to the ladder from the catwalk. This is not offset. It would be a single direction fall into the ladder opening and as such, a ladder safety gate is required to protect your employees when a ladder is installed in the above orientation.
Most areas are not offset. A good rule of thumb is that if you can fall into the ladder opening with a single direction fall, then you are not offset. The only example above that didn’t need a gate was the second ladder location. With that orientation, you would fall onto the ladder landing and then hit the rear railing, not fall through the ladder opening.