OSHA 1910.28 Ladder Change is Live

OSHA’s November 19, 2018 fixed ladder changeover has officially come on their standard 1910.28. What do you need to know to ensure you are meeting OSHA fall protection standards for your fixed laddersOSHA 1910.28 Ladder ChangeIf you have an existing fixed ladder more that 24’h that was installed before November 19, 2018, it should already have a cage on it.  The previous OSHA standard 1910.27 required cages on all ladders over 20’h. You have until November 18th, 2036 to retrofit the caged ladder with a personal fall arrest system. Until then, you are grandfathered in under the OSHA standard that was in place at the time of install. If your climb is 24’ or less, you do not need to retrofit the ladder at any time with a personal fall arrest system.

A-Mezz Personal Fall Arrest System Meets OSHA 1910.28

A-Mezz Personal Fall Arrest System Meets OSHA 1910.28

Note that if you modify or replace an existing ladder (over 24 feet high) that was installed before November 18, 2018, you will need to retrofit the ladder with the personal fall arrest system at that time. Replaced ladder sections are not grandfathered in under the prior OSHA standards – 1910.27.

Any new ladders over 24’h will need to be installed with a personal fall arrest system. You can still have a cage installed on the ladder “provided it does not interfere with the operation of the system” (1910.28(b)(9)(iv)).

These changes pertain to “fixed ladders that extend more than 24 feet (7.3 m) above a lower level.” The big change for lower ladders is that a fall arrest system is now not required until you are over 24 feet, whereas the code used to require cages or personal fall arrest systems for climbs over 20’ (1910.27(d)(1)(ii)).

You can also now run your ladders a maximum 150’ in a single climb if using a personal fall arrest system or ladder safety system (1910.28(b)(9)(ii)(B)).

The previous OSHA fixed ladder standard had stipulated a 30’ maximum climb before landing platforms were used to break your climb up into shorter climbs. I.e. before November 18th, 2018, a 150 foot climb would require five separate caged ladders and four separate landing platforms. OSHA 1910.28 will let you now have just one ladder with a personal fall arrest system, cutting fabrication costs, delivery costs, and installation costs.

Please contact us at A-Mezz Industrial Structures to get more information on our fixed ladders, our ladder cages, and our ladder personal fall arrest systems.

 

A-Mezz Rigid Track Personal Fall Arrest System

Personal fall arrest systems are causing cages to go out of vogue with OSHA. As of November 2018 they will not count as fall protection on new fixed ladders and they will only count as fall protection on existing ladders until November of 2036. Note that if an existing ladder is modified at anytime, that modified section of ladder must be retrofitted with a personal fall arrest system at that time. 

Personal fall arrest system with body harness and trolley

Personal fall arrest system in use with body harness and trolley

We now carry a rigid fall arrest track that, when used in conjunction with a trolley and body harness, will meet OSHA’s new requirements for fall protection. The rigid track and trolley allow the climber to move freely up and down the track without needing to push, pull, or even touch any part of the fall arrest system.

Should an accident happen, your foot slips or you fall, the trolley on the fall arrest system will automatically lock onto the rigid rail, stopping your fall.

Tracks are available in 316 Stainless Steel or Aluminum with an anodized finish. The trolleys are designed for a single user and have a capacity of 310 lbs. Note: Two users are permitted to use a single track when used for rescue purposes, but never the same trolley. With that in mind, we suggest the single track and two harnesses and trolleys.

One track/trolley may get you by for most things, but if you ever need to have more than one person on the roof at the same time you will need to have a harness and trolley for each climber. If you do not, the first climber has to get to the roof, remove the trolley and harness, lower it by rope to the lower person who then has to put on the harness and climb up. Likewise, when work is done, one person has to climb down with the harness and trolley and then remove it, tie it to a rope for the upper climber to pull up, put on the harness and climb down… It doesn’t make much sense to us either.

Close up view of A-Mezz personal fall arrest systems utilizing rigid track.

Close up view of A-Mezz personal fall arrest systems utilizing rigid track.

The rigid tracks are installed in the middle of the climbing side of the ladder rungs. The fall arrest system clamps around the ladder rung every 4’ to 6’ to secure and can have multiple pieces of rigid track spliced together to accommodate long climbs without requiring a single long rail to be shipped, which saves on shipping costs. Often the increased cost of the system is offset almost entirely by the fact that the ladder does not need to have a cage anymore. Cages are costly to manufacture and especially to ship. Taking up 4’x4’x34’ of space on a truck isn’t cheap. We have seen some freight costs come back almost 1/7th what they were compared to caged ladders.

 

A-Mezz Ladder Install in Muddy Conditions

Springtime Muddy Ladder Installation

Ahh… Spring time in Ohio. The flowers, birds, oh and MUD.

A-Mezz Ladder Install in Muddy Conditions

A-Mezz Ladder Install in Muddy Conditions

We got a call from a builder with with a newly constructed structure – so new that there was no paved access yet – and they needed a ladder to gain access to their HVAC rooftop units. The building height was over 30’ and we had some options on how to access the roof based on OSHA’s new regulations.

The first option was a straight, uncaged ladder 35’ high with a personal fall protection cable. That is the new OSHA requirement on all climbs over 24’. The pros of the cable/track systems are that the climber wears a harness and clips onto the fall arrest system so that if he falls, the system stops his fall. The downside is those systems require the climber to have a harness and proper equipment to utilize the cable/track.

For this site the customer chose to go with the second option. We used a lower, uncaged ladder to get them up to a mid landing under 20’h. Then we used a second ladder with cage to climb from the intermediate landing to the upper roof. This setup was slightly more expensive up front but did not require the purchase of additional harnesses, trolleys and maintenance that the personal fall arrest systems required. Additionally, the cage is always there. This provides a safety benefit always, whereas the personal fall arrest systems only provide a safety benefit if the climber is wearing a harness and has the proper equipment. By utilizing the intermediate platform, no climb between platforms is over 24’ so the customer will not have to retrofit their ladders with personal fall arrest systems in 18 years when OSHA’s grandfather rules expire for existing ladder systems.

We had to hold off on install for a couple weeks as the ground thawed early in Ohio and there was way too much mud for our equipment to get to the install location. Luckily we caught a break and a few dry sunny days slightly helped dry out the site – being Ohio, if we didn’t get out to the site when we did, the spring rains could have pushed things off for months until things dried up.

Trying not to bury our axels in the mud, we got the upper ladder into place and worked down from there.

Upper Caged Ladder Being Lifted into Position

Upper Caged Ladder Being Lifted into Position

We fabricated the upper ladder with our self support walk-through handrail because the wall included a short parapet and we didn’t want to have the ladder setting on the metal capping.

Self supported walk-through handrail detail

Self supported walk-through handrail detail

On the lower ladder we included our lockable rung door so that unauthorized people could not climb the ladder.

Completed Installation of Ladder System

Completed Installation of Ladder System

With a crew of two men and one morning, the ladder system was installed (despite the mud) and the customer has safe, OSHA and ANSI compliant access to their roof. A-Mezz took care of everything from design, detail, fabrication and installation and we were able to educate the customer on all of their options and costs. The project was done on time for the amount budgeted.

Catwalk Bridges Can Save Space and Improve Efficiency

Recently we’ve been out to a local shop for a lot of projects. This time we were called to supply some catwalk bridges. This helps them better utilize their existing space by gaining extra storage and workstation space from the areas they already had. They have several buildings in their facility that were capable of housing light storage on top of them. Ordinarily, the easiest way to access these spaces is through a pre-engineered steel staircase. The problem you run into when you have many buildings in relatively close vicinity to each other is that floor space is a premium; you can’t afford to block off aisle ways with stairs, and even if you have the space to accommodate multiple stairs to access multiple buildings, it is not very efficient having to run up and down stairs from one structure to go to another.

One stair was put in place to access a central building and then a couple of catwalk bridges were fabricated and installed to access the ancillary modular buildings. The catwalk bridges were fabricated so they could be lifted into place with a forklift truck. This allowed for quick, easy installation. This also allowed the customer to remove them relatively quickly should they need the additional vertical clearance to bring larger machinery through their aisles.

Catwalk bridges between block wall and modular building

Catwalk bridges between block wall and modular building

Attachment to their existing cinder block structure was easy, but mounting to their modular buildings required some extra consideration. Modular buildings are weakest at the panel locations. We supplied angle so the customer could span the angle from multiple posts on the building and then fasten the bridge to the angle. This distributed the load of the bridges across two sturdy posts per side instead of hitting a potentially crushable panel.  The catwalk bridges were not going to be centered directly over their panels so the angle was sent extra-long to allow flexibility in their bridge locations.

The customer now has access to multiple interior building tops for additional workspace and storage, and hasn’t sacrificed much room on their floor now that they utilized crossover bridges to open up their previously unusable  spaces.

OSHA Changes Ladder Fall Protection Requirements (OSHA 1910.28)

OSHA is on fire! Breaking news! WOW!

Ok now that we’ve got that out of our system… We don’t usually have many changes out there when it comes to OSHA standards but there are some industry changing updates coming that will change a lot of things.

Cages will not be required on fixed ladders after mid November of 2018.

Caged ladders to be phased out for other fall protection options

Caged ladders to be phased out for other fall protection options in 2018

Currently, under OSHA standard 1910.27 cages are required on ladders where the climbs are over 20’h. In OSHA’s new standard (OSHA standard 1910.28) taking effect 11/19/2018, ladders will not be required to have fall protection until their height is over 24’ (24’-0-1/4” requires fall protection). OSHA will also be requiring ladders installed after 11/18/2018 to have fall protection in the form of a personal fall arrest system or ladder safety system (not a cage). If you have cages now, don’t worry, you will be grandfathered in for twenty years.

So, why the change? OSHA is aligning the fixed ladder standard to be more in line with the ANSI standard A14.3, which in 1979 changed its fall protection height requirement from 20’ to 24’.

Why are they telling us now when the rule won’t go into effect until 11/19/2018? OSHA wants to give the industry time to update products and procedures before they go fine crazy. You CAN now follow the new OSHA rule 1910.28 even though it is not in effect yet. You would not be meeting the current OSHA standard, but you would be in compliance with the future OSHA standard. OSHA would consider this a “de minimis violation”. De minimis violations are violations of standards which have no direct or immediate relationship to safety or health, and do not result in a citation, or penalty and need not be abated. 

How does this help you? Well, if your floor to floor height is between 20’ and 24’, you will no longer need to have a cage on your ladder. First off, this can save you LOTS of money. Why?  Not only is it easier to fabricate an uncaged ladder, but there is less steel involved in making the ladder, and also, due to the size a caged ladder takes up on a truck compared to an uncaged ladder, caged ladders can cost 2-4 times as much to ship than their uncaged counterparts.  Another advantage of losing the cage is that you decrease its visibility from the roadside. Without the large cage the ladder is tougher to see from a distance, increasing your buildings visual appeal as well as decreasing the chance that kids looking for a cool place to skateboard, copper thieves, and other people you don’t want on your roof will see the ladder as they pass.

All this being said, when OSHA’s standard mandated cages on climbs over 20’, A-Mezz still offered cages on ladders that only had a climb of 10’ or so and we will continue to offer cages for customers who prefer the added safety of a cage for those shorter climbs. We have gotten feedback from many customers who prefer having a ladder cage because that safety barrier is always in place. You can’t forget to bring a harness with a cage so safety is increased. It is the same argument that makes ladder safety gates so popular and efficient as opposed to ladder chains. Chains only work if the person before you closed them. Ladder safety gates are always in place, always swing closed and always protect you. The same goes for a fixed ladder cage which adds some protection for climbers regardless of whether they have a ladder harness or not.

Fixed Ladder Installation – the process from start to finish

A customer called asking for a safe and secure means of accessing their roof and us to do a fixed ladder installation. They have a building that has multiple tenants and didn’t want to have to go through the tenants’ space every time roof access was needed, so an interior ladder and roof hatch combination was off the table. This happens more often than not either because they don’t have a good location inside to mount the ladder or they don’t want to make a hole in their roof.

We went out for a preliminary site visit to verify what the job would entail. The location that was chosen to mount that ladder at was flat from floor to roof. There were no gutters so we would not have to worry about having to either start and stop the gutter and add another down spout, or add a step across platform at the top of the ladder to keep within OSHA’s requirement of a maximum step across a distance of 12”.

Installation site for caged ladder

Installation site for caged ladder

There was a slight parapet at the top of the wall so we set up the extension ladders to verify that the parapet was under 14”high so we would not need to have a crossover ladder with return on the back. We did elect to modify the walk through handrail to remove the return down to the roof to allow more flexibility with installation. Using the self supported walk through handrail allowed a proper fit regardless of the parapet thickness.

Materials were fabricated and shipped to the jobsite where the installation crew attached the lower and upper ladder sections together with the supplied brackets. Next, the ladder was hooked up and elevated into place by a forklift boom. By securing the ladder a little lower than the top, but well past the weight ½ way point, we were able to safely use a shorter, readily available lift and avoid the added cost of additional machine rental.

Lifting the fixed ladder into position

Lifting the fixed ladder into position

The ladder was also outfitted with the LG6 6’ security ladder rung guard to prevent unauthorized access to the ladder. Once hoisted into place, ½” sleeve anchors were inserted into holes drilled into the block and turned until expanded properly, securing the ladder to the wall. For this ladder 18 anchors were used, distributing the 650# ladder and 300# capacity load to well below the tension and shear values for sleeve anchors with the recommended 1-7/8” minimum embedment and a 4:1 (25%) safety factor. Installation was completed in just one morning by a crew of two.

Completed installation of fixed ladder

Completed fixed ladder installation

Steel Fixed Ladder Handrail Options

Does my ladder need a handrail?

Almost all ladders will have an extension at the top, with the only exceptions being ladders accessing roof hatches, manholes, floor doors, or anything else that closes over the top of the ladder. If you are exiting the ladder to the side or going to an offset platform due to the 30’ maximum climbing distance between ladders, you will need to add four more rungs above the platform. Those rungs are only to be used for hand-hold only, to give you something to grab onto to safely exit the ladder.

 

Side step ladder platform for climbs over 30' in length

Side step ladder platform for climbs over 30′ in length

If the ladder is going up to a wall, to a roof, or to a mezzanine, then you will need extensions on the ladder for the “walk-through” exit of the ladder.

We have three different designs of walk-through handrails and I’ll go into the details on each of them below.

Steel ladder handrail options

Steel ladder handrail options

The first design, the “8” shape, is our standard ladder design. This is the most commonly used handrail setup as it allows for the top of the walk-through to mount to the landing surface, providing the greatest rigidity at the handrail. It also makes installation easy, as there are no questions where the top rung mounts; it is always installed properly meeting the top of the landing surface as required by code.

In cases of short parapets or locations where you cannot have the walk-through handrail anchor to or even set upon the roof you would use the second “P” profile, our “self supported walk-through handrail”. This handrail design works well when there is a parapet under 14” high that the handrail mounting pads would not line up with. It is not a necessity to use the “P” shaped handrail in those instances. Many installers still prefer the “8” layout for the added cross brace back to the ladder. When installing a ladder with our self-supported walk-through handrail, be sure to install properly, with the top rung level with the top of your roof. There is no foot pad at the top to ensure this is done, so installation just requires a check to be sure of compliance.

The last ladder handrail design is our “customer supplied walk-through handrail”. This is used in instances where the installation location has existing railing and handrails that they want to weld the walk-through handrail to. This is useful in locations where space is minimal and existing site conditions allow for field welding to existing rails.

Not shown is our step across platform, which is essentially a crossover used when site conditions require the ladder rung to be more than 12” away from the landing surface as required by OSHA standards. Most commonly, this is used on locations with gutters that are more than 5” off the face of the climbing side of the wall.

OSHA 1910.27(d)(3)

“Ladder extensions.” The side rails of through or side-step ladder extensions shall extend 3 1/2 feet above parapets and landings. For through ladder extensions, the rungs shall be omitted from the extension and shall have not less than 18 nor more than 24 inches clearance between rails. For side-step or offset fixed ladder sections, at landings, the side rails and rungs shall be carried to the next regular rung beyond or above the 3 1/2 feet minimum (fig. D-10).

Ladder Modification to Meet OSHA standards

control_tower_ladderWe recently were called out to look at a ladder that did not meet OSHA standards (1910.27) for clearance on the back side of the ladder. The ladder also had two angles of climb as shown in the above photo. When climbing up the ladder, the concrete walk was too close to the ladder for you to safely grasp the rung and also to put your foot on the rung while climbing. The ladder was accessing the top of the traffic control tower at an airport, and as such, we had to work around a variety of factors to ensure a proper replacement or modification of the ladder could take place without interrupting operations. As the install location was at an airport, the use of a crane to bring a replacement ladder to location would have been a logistical nightmare. We decided that whatever the solution was, it was to be brought up from the inside of the tower.

control_tower_ladder_option1Our first option was to remove the ladder and replace it with a 90 degree ladder. That is the most common fixed ladder type. There were, however, issues with supplying a replacement ladder.  First off, the concrete walk and rail were extended beyond the top of the tower. This meant that our replacement ladder would need to be very far from the structure in order to give us the required 7” clearance behind the ladder at the concrete walk location. That is not a deal breaker, but holding so far off the structure would have also required an extra-long crossover to reach the tower roof.  OSHA allows the ladder to have a maximum 12” step across at the top of the ladder. As the ladder has to stand 7” off of the wall (or the furthest obstruction off the wall) you can get by without a step across platform if the obstruction is 5” or under (5+7=12). The replacement ladder would have been very large. Ordinarily, this too can be dealt with by using our modular line. Our Modular Fixed Ladders come in pieces no larger than 7’L. Each ladder section bolts to the next one and has a pair of standoff brackets before and after the splice.

We could not accommodate additional standoff brackets required by the modular design so we would have needed to weld each splice together. Again, this was not a deal breaker either, but it did make this option less economical than other options.

control_tower_ladder_option2We decided that it was more economical to modify the existing ladder. The top of the ladder was already angled at an 81 degree angle. In the field we ran a laser down the ladder from the top to see where we would land if we kept that same angle throughout the climbing run. By cutting the ladder at the bend, and then cutting each of the lower standoff brackets, we were able to gain close to a foot of clearance at the concrete landing, well within the acceptable tolerances of OSHA’s standards. This option was not without its challenges though. As the ladder was going to be sticking off the wall even further than before, we were concerned about having a stable climb.

Here is the original ladder with the standoff brackets back to the structure.

Here is the original ladder with the standoff brackets back to the structure.

control_tower_ladder_afterWe added cross bracing across the two standoff brackets to stiffen the ladder up with the extended bracket length. After modifying the ladder, the bottom rung was still within the 14” allowed by ANSI A14.3, so no additional ladder rungs were required. Each welded location was then sanded down to remove any sharp edges or burrs and painted with a rust inhibiting primer. The end user was going to have their maintenance department repaint the ladder after completion of the work to help cut down on costs.

The ladder modification was completed at budget and within the scheduled time. Most importantly, the customer now had safe access to their roof. If you have a unique situation like this, give us a call. We can help you come up with the solution that fits your site requirements and budget, too.

completed_control_tower_ladder

Do I Need a Swing Gate on My Fixed Ladder?

 

Walk-thru fixed ladder with cage

Walk-thru fixed ladder with safety cage

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.

Fixed ladder mounted to side of platform

Fixed ladder mounted to side of platform

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.

Top view sketch of side mounted fixed ladderway opening

Top view sketch of side mounted fixed ladderway opening

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.

Fixed ladder with offset landing platform

Fixed ladder with offset landing platform

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.

Top view sketch of offset mounted fixed ladderway opening

Top view sketch of offset mounted fixed ladderway 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.

Ladderway opening on side of catwalk

Ladderway opening on side of catwalk

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.

Top view sketch of catwalk side mounted fixed ladderway opening

Top view sketch of catwalk side mounted fixed ladderway opening

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.

Stay safe everyone!

We received a sobering message from a customer looking at our caged fixed ladders today:

 “My dad fell off of the roof to his death in June while trying to come down the ladder he had rested on the side of the building.  I believe his foot got caught in the rope.  If he had had one of these ladders this would not have happened.”

Stay safe out there everyone. I know that the above was just a random accident but if there is the chance that you can prevent those, especially after hearing about what can happen, why wouldn’t you?  Taking precautions and doing things the safe and right way may take a little longer or cost a little more, but going home to our loved ones at the end of the day is worth any price.

Our sincere condolences are with this customer and their family and hopefully sharing this story will cause someone else to take a moment to look around and make sure they are taking all necessary safety precautions. If you are unsure if you are doing something right, ask someone.

With a little help we can all make it home safe tonight.