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.

 

Drain Thru Rubber Matting for Snowy Entrances

Winter is fast approaching, and for many of us that means frigid cold temperatures, snow, and dangerous ice.

All around me I see neighbors battening down hatches to prepare for a long and dark few months. However, preparations aside from plastic window coverings often go forgotten. With the holidays just around the corner, many of us have family on our minds, and it personally has me worried about slip prevention, especially for our youngest and oldest members.

Solutions to combat slipping can be time consuming as well as expensive; luckily, there are many simple preventive measures that can be taken to ease this worry. In my opinion, the simplest preventative measure is a drain thru mat for each of your entryways — and don’t forget your garage entrance after all of that snow shoveling!

Our Olympian series drain thru mats are 100% recycled material made from trim rubber used in tire manufacturing.

Olympian series drain thru rubber mats

These mats are built to withstand the most extreme conditions. While other drain thru mats will crack and fall apart with the cold, these will last and last and last. Olympian mats show no visible cracks or fractures in temperatures as low as -45 degrees Fahrenheit! Then when the spring and summer months come, there is no need for them to be replaced, as our Olympian series shows no signs of deterioration at even 400 degrees Fahrenheit! Whether it’s hot or cold, this mat is built to take it!

detail of drain thru rubber mat

We are already late in the year, and while most slip prevention projects require tedious installation and warmer temperature for adhesives to adhere, this mat is heavy enough to simply be laid out, while still being light enough to hang dry when needed.

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.

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.

Bi-directional gates are not SAFETY gates

Safety gates can be confusing. Don’t let them be.

Safety gates can be confusing. Don’t let them be.

We often get calls from customers looking for bi-directional safety gates, i.e. gates that do not have a stop and swing both in and out. Often these customers are looking for gates for staircases to hang signage on in order to “restrict access” beyond certain floors in staircases. The problem is that these gates do not meet OSHA standards for fall protection. OSHA’s guard rail standard requires a top and mid rail and requires the gate to hold back a minimum of 200 lbs. of pressure at the top rail. By definition, bi-directional gates do not meet that requirement, especially when used at the top of stairs. The best option for these customers is to use a self-closing and self-stopping gate, similar to our AG series of gate.

Stair safety gate mounted with the orientation requiring user to pull the gate towards them to walk downstairs. Coming upstairs, the user would simply push through the gate.

Stair safety gate mounted with the orientation requiring user to pull the gate towards them to walk downstairs. Coming upstairs, the user would simply push through the gate.

When used at the top of stairs, these gates can be positioned to require anyone going down to a restricted area to pull the gate towards them and descend the steps. They can also be positioned at the bottom of the steps requiring anyone going up the steps to pull the gate toward them to ascend the steps.

What you cannot do, and what is not safe by any means, is to do the opposite. If you install a bi-directional gate at the top of a staircase and someone falls into it, odds are they are going to have a very bad injury.

Bi-directional gates are not fall protection. They can actually give a false sense of safety creating more accidents.

Bi-directional gates are not fall protection. They can actually give a false sense of safety creating more accidents.

So take the extra second and install the proper gate for your location. Being safe is a LOT cheaper than cutting corners.

Tempered Safety Glass Windows

This past week I had a customer who had a slight misunderstanding of what tempered safety glass was, so I thought I’d take a minute to discuss just what tempered glass is and the safety features it provides.

Tempered (or toughened) glass is a type of safety glass in which chemical or thermal treatments are used to strengthen it so that it is harder to break then standard glass.  Tempering compresses the outer surfaces and puts the inner surfaces of the glass into tension.  When broken, these forces cause the glass to crumble into granular chunks as opposed to larger sharp edged pieces, and are much less likely to cut you.  This is why auto manufactures use tempered safety glass in the side and rear windows of cars.

If you’ve ever had a broken side window on your car, you’ve seen how when tempered safety glass breaks it shatters into hundreds of small grainy pieces all over the inside of your car.  If you’ve broken your windshield though, you can see a spider web of cracks throughout the window, but it typically stays in its frame as opposed to filling the car with pieces of glass.  Auto manufactures do something different with the windshields.  They use laminated safety glass.

If the goal is to keep your modular building‘s window in its frame if it breaks, you’ll need to look at either wired glass or laminated glass.

Winter Weather Tips

It’s getting colder now and it’s time for some winter weather tips to keep things running smoothly whether you’re at the shop or out on the road.Snow storm traffic jam

  1. Keep a 5 gallon bucket with salt by each of your entrances along with a shovel. Snow and ice buildup can not only make it tough for people to get into your shop, it can also hinder egress in case of an emergency. Be sure to open the emergency doors and shovel/salt around them. Drifts of snow and ice can build up on the outside wall even if there is only a little snow on the ground.
  2. Have entry mats and/or a dry mop by the entrances to your shop. Wet boots trekking in snow can be a dangerous slip hazard.
  3. If you have exterior silcocks (spigots) be sure to remove hoses from them. Even if you have a frost free silcock, it will freeze with the hose attached.
  4. If there is ice on your windshield there is ice on the road. It doesn’t have to be packed up deep to be a problem. Often a thin sheet of ice can cause a big problem, especially when people aren’t expecting it.
  5. Watch the spray from tires – if spray is coming off other vehicles’ tires it’s likely the roads are wet as opposed to being ice covered.
  6. Pack extra supplies. Be sure to bring extra supplies in your truck in case you end up sitting in a back-up, stuck in the snow, wrecked or spun out. Blankets, hats, gloves, wool socks, hand warmers, energy bars, bottled water, a bag of road salt or sand, a small shovel, tow rope, booster cables and emergency flares are a good place to start.
  7. Make an electronics bag for your car. If your job requires using cameras, two way radios, cell phones, laptops or another portable electronic device like a laser level or laser measurer, pack those items all in one bag that you can take to and from your car, along with some extra batteries. Remember, in cold weather batteries are not as productive and electronics can stop working, so it is best to take them indoors with you instead of letting them chill for a prolonged time in an unheated trunk. Packing these items in one bag makes it quick and painless to take them with you.
  8. Stay dry. Whether you are directing traffic, offloading a truck, or maintaining or installing equipment, keeping dry is the first step to preventing frostbite and hypothermia.
  9. Layer properly. Cotton tee shirts offer no insulating value to you when you get it wet, yet many people still wear them as they go off to work outdoors. Natural fibers, wool or silk are amongst the best insulators when damp. There are also many good synthetic materials out that do just as well.  Remember, even if you start off warm and dry, when you work, you sweat, and when you sweat, you get damp, and when you get damp in cotton, you get cold.
  10. When working outdoors, take regular breaks from the cold. Hop in your truck for a warm beverage that you keep in a thermos. This will warm you from the inside out. Same thing goes for eating. Hot soup will warm you up quicker than a brown bagged sandwich.
  11. To help prevent your fuel lines from freezing up, keep your tank at least half full. If the vehicle is going to park for lengthy periods, fill the gas tank beforehand.