copyright Barrett Miller, MEd,OHST
The Sinagua Indians farmed the lush Verde valley of northern Arizona about nine hundred years ago. To reach a limited water supply, they built village homes inside the lip of a collapsed limestone aquifer.(1) Their community sat hundreds of feet above the floor of a high canyon.
A network of ladders connected family dwellings. They could be removed for defense. The ladder itself carried both a practical and ceremonial significance. The Sinagua people were master climbers. Centuries later their descendants, the Pueblo and the Navajo people, would pioneer the techniques used for climbing steel structures in skyscrapers. Occasionally, even Indian climbers died in falls.
Falls from heights are a safety problem in industry and in homes. At least three hundred people a year die in simple falls from ladders. Ladders account for about 100 thousand injuries each year. The distinction between ladder accidents and elevated fall accidents is blurred in accident statistics. We know the effect of falls. A person falling from any height will accelerate until he hits a fixed object. The results will depend on several variables, but, statistics show that in a fall of eleven feet or more, 50 percent of victims will die.(2)
There are hundreds of specialized ladder applications and almost as many ways to get hurt. Window washer's ladders rest against the glass, and extension ladders designed to lean on overhead power lines. For at least two thousand years, climbers used three legged fruit picker's ladders to harvest olives in Lebanon. There are even single beam ladders with rungs coming out of the side.(3) Each ladder type has a specialized application.
An employer's duty is to provide fall protection. Ladder use should be understood in this broader context. It's wrong to believe that a climbing tool, perfect in one situation, will automatically work in another. Your ladder may be too long or too short for the job. Its feet might not match the working surface. You may need to replace it in the middle of a job. Remember that elevated falls account for one third of industrial accidents, and half of fatal construction accidents.
The Consumer Product Safety Commission reports that more than 90,000 people receive emergency room treatment for ladder accidents each year.(4) Elevated fall accidents accounted for 661 deaths on the job in 1994. That is fourteen percent of total occupational death that year. In all, 111,300 persons were injured in elevated falls in 1994.(5) A ladder can slide, tip, slip, or break. It can also catapult a climber. Climbers are frequently hit by passing carts, cars and even trains. In some cases, federal codes require spotters and barricades. Ladders propped on top of another object to gain height or convenience often move. If the floor surface or the upper surface are slippery, the ladder may slide away from the climber. A weak leg can compress then act as a spring to catapult the climber.
Some people believe that ladder falls are always the fault of the victim. Many are blamed on a lack of common sense. OSHA research, on the other hand, concluded that 100% of ladder accidents might be eliminated with proper attention to the application of equipment, and the proper training of climbers. Human failure causes most ladder falls, but the preventable error is often administrative; not the fault of the victim.
In one half the ladder accidents investigated by the Bureau of Labor Statistics, the worker carried materials in his hands as he climbed. (6) This practice contributes to slips. Materials should be raised to the work station on a tether. In many accidents, either the ladder or worker slipped. A ladder should always have four point contact with the working surface, and pressure on each leg should be proportional. The climber must always maintain three points of contact with the ladder. Safe contact can be maintained with two feet and one hand. Weight is centered within the rails of the ladder. If the working surface is slippery or unstable, the worker must tie or strap the ladder to the rear surface at the top and bottom. These limitations make the ladder too restrictive in many applications.
Straight and extension ladders are legally called self-supporting and non-self-supporting ladders. These mass produced, tools exist in both a social and legal context.(7) Our efforts here introduce these common ladders and the corporate responsibility for their use A ladder is a device used to gain safe access to a work station. Its secondary use, as a work station, is limited. Painters, line men, and many installers can use a ladder successfully. However, any job that requires the worker to reach outside the vertical rails or to manipulate equipment from the elevated workplace requires special consideration. The example of Max, the X-ray technician, provides an example.
A Lesson From Max
Max used the center (fly) section of an extension ladder to reach the top of horizontal pressure tanks in a factory. The tank was twelve feet in diameter and forty feet long. The X-ray work had been done the same way for twenty-five years. Factory managers frequently used the fly section independently because it was light and portable. Its narrow base allowed access to the center of the tank.
This ladder did not have slip resistant feet. The working surface was concrete covered with flux and other welding byproducts. Sometimes the floor was slippery. Max found it impossible to secure the ladder to his satisfaction, but blocked it with dunnage he thought would work. He climbed about ten feet and began to move horizontally to the round surface of the tank. There, he would leave the ladder and work directly on the rounded surface of the tank. At the transition point, the bottom of the ladder kicked out. Max fell.
It is useful to look at the shortcomings that led to Max's injury to find specific actions and inaction's that contributed to this accident.
1. The fly section of the extension ladder did not have slip resistant feet. There are devices that widen the base of ladders; they might have worked here. Max used dunnage to block the ladder at base, but that was inadequate. Blocking is not a preferred technique. Strapping or lashing the ladder in place is better.
2. In spite of the repetitive process, no attachment points for ladders or personal restraint devices existed in the tank factory. They should be included.
3. This accident happened at the point where Max attempted to move from the ladder to the top of the tank. This part of the process was foolish. The BLS study showed that in one half of ladder accidents, falls happened as the climber attempted to move to a second surface. You cannot allow an employee to walk or work on the side of a rounded surface fourteen feet above the floor unless he uses personal protective equipment. The factory could have easily installed a horizontal steel cable to secure waist belts and lanyards.(8)
If the job requires the worker to move more than twelve inches horizontally to a second work surface, he must be secured with a restraint. A ladder is a three-point device. If the climber cannot keep three limbs in contact with the ladder, maintain balance, and perform a work task, another device must be used as a work station.
4. Max felt that climbing in this factory was unsafe, but believed that if he refused to do the job as he found it, he would be replaced. Other employees felt the same way. We don't know if the employer would fire Max for complaining, but his shared belief prevented corporate supervisors from getting information they needed.
Personal Protective Equipment
A NIOSH study classifies ladder falls into one of three broad categories. (1) Accidents in which the wrong ladder was used to do a job. (2) Accidents in which the ladder failed due to the physical condition of the ladder or the condition of its supporting surface. (3) Accidents in which the ladder was improperly used. To this list of shortcomings, we add another. There are accidents in which the ladder was not the right tool for the job, and where it cannot be safely used without personal protective equipment.(9) Several months after Max's accident, the tank factory hired its first safety engineer.
In 1990, OSHA published a clarification for employers in the Federal Register. It explained the duty to provide fall protection and options available.(10) Employers must provide a definable level of protection for employees working four feet or higher above the floor surface. If there is a vertical transition of more than eighteen inches, a step, stool or ladder or step must be used as a transition. There are few restrictions on the way fall protection is provided, but there is a concept we will call "equivalency," to consider. Any method chosen must be as secure as the level of protection provided by a scaffold with two rails and toe board.
The use of personal protective equipment is an acceptable substitute for the security of a scaffold. In 1995, another interpretation expanded an employers responsibility to include the assessment of fall hazards and the duty to provide safe countermeasures. It also created the duty to train employees.(11)
Max found himself trapped in a crisis of "perceived accountability." His immediate employer, saw himself as a supplier of skilled x-ray technicians. Schools provided Max with some safety training. Applications varied, so his employer relied on each factory contractor to train employees on specific job steps.
In most large factories, the step by step production management techniques define each job detail. Some factories even conduct time and motion studies to determine each movement of the worker's body. This wasn't true here. Max found himself in a factory that ignored most detailed production management functions. The tank factory provided ladders and pointed to the job. The rest was up to Max.
Everyone knows that you can't stand on the top of a step ladder. Apparently not. Several years ago, the building manager for a large insurance company called the author to his office. We were contractors in his building. The author was across town and didn't arrive at once. The building manager was livid. Without a word he marched across the campus to another building. There, a ladder stood outside of the doors of a busy elevator. On the top cap, stood our installer. His head and shoulders were above the false ceiling. There was no spotter, no barricade, and the corridor was full of people. Our installer stood on the top the stepladder, asleep. His balance had been maintained by the light steel structure of the false ceiling. According to witnesses, our man napped on the ladder for an hour.
Fortunately, there was no accident. The worker's behavior was stupid and reckless. Should he be fired? He might have been killed. There is a more painful question. Was the building manager less reckless, less negligent, or less stupid? How could he let a man continue to be at risk for a full hour when the situation placed the worker in immediate peril? If he was killed, would the plant manager have been less responsible than the worker that fell?
No corporation can ignore the dangerous behavior of vendor employees, or their lack of training. The duty to provide a safe workplace is not dependent on who provides the paycheck.(12) To the degree you create a hazard, control it, or have the responsibility for correcting it, the duty to initiate safe practices is yours. In some situations, federal codes forbid you to delegate safety responsibility at all.(13)
You must have a formal program to provide fall protection. Corporate responsibilities begin with the choice of the tools for each job. If you use a repetitive process, conduct a survey of climbing jobs. Determine what type of ladder to use, and if a ladder is the right tool for the job. A survey includes an assessment of the need for personal restraint systems. It also includes the engineering of tie-off points at an elevated position when you need them.
The Competent Person
Employers now have the legal duty to inspect(14) the site where his employees will work. This can be a shared responsibility. It affects you even if employees are working under the day to day supervision of a primary contractor. At least one competent person must understand the process. This employee must be able to identify hazardous or dangerous conditions and evaluate the risk of falls. You must train him to use personal protective equipment, including the selection of anchor points and application of personal restraint systems. If he doesn't repair equipment himself, he should supervise a competent carpenter. He should know how to detect hidden defects. Ladders are a deceptively complex subject. He must have specific competencies in the purchase, inspection, and repair of ladders.
The careless purchase of a single ladder can kill a worker. The introduction of a ladder in a work site is important. Tom provides an example. Tom, who owns several businesses, purchased a stepladder for use on his construction business. He believed ladders were a simple subject. Tom chose a ladder by brand recognition and price. It cost about sixty dollars. Through ignorance, he had purchased a Type III household ladder with a maximum duty rating of 200 pounds with their equipment. . Some workers weighted up to three hundred pounds. Over time, carpenters dutifully nailed pieces back on the ladder when they fell off. He used the ladder in his construction business for three years.
The ladder became shaky and several carpenters complained. Tom moved it to a convenience store he owned, where it would be used occasionally. One evening, the disabled husband of an employee decided to help by vacuuming the air-conditioning ducts. By this time, the strength of the thin ladder leg had become so weak that it flexed easily, and functioned as a spring. The leg compressed under his load and as the climber shifted his weight, the leg kicked out and threw the climber to the floor. There was a serious injury, and an expensive law suit.
Everything from oil barrels to unused pallets are appropriated as work platforms. In most situations, a ladder is a better tool. But, a ladder can be as dangerous as any makeshift device. Typically, you remove a ladder from service before it breaks or becomes too shaky to use. Federal codes require a ladder inspection routine and the tag-out policy for suspected ladders.
When the work of ten or more employees involves climbing, a single competent person should be responsible for a safe climbing safety. In small companies, this may be you. The purchase, inspection, repair, disposal, and training are all duties of a delegated specialist trained to recognize hazards and respond correctly.
OSHA defines this competent person as:
"One who is capable of identifying existing and predictable hazards in the
surroundings or working conditions which are unsanitary, hazardous, or dangerous to
employees, and who, has authorization to take prompt corrective measures to eliminate
Choosing a Ladder
Ladders are disposable items. Their useful life depends on construction quality, conditions of use, care, and general history. Was the ladder exposed to the weather, or dropped? Are bends and twists serious enough to remove the ladder from service? An average employee should be trained to recognize a broken or shaky ladder, but a specially trained person is necessary.
What is a ladder's ultimate strength? What is its usable height? What is its usable load specification. You should be aware that some ladders are fraudulently marked.(16) Occasionally a company will provide instructions on a ladder that are incorrect or dangerous. Second we are concerned with its composition, and how expected use influences our choice. If one is going to use a ladder around electricity, and most will, it must be wooden or fiberglass. Each ladder has limitations.
Federal directives make employees responsible for complying with all equipment and practice standards found in national consensus standards. This is true even if you never have heard of the standards.(17) Most ladders carry a seal certifying compliance with OSHA and ANSI standards. It is important to note that neither OSHA nor The American National Standards Institute tests or certifies ladders. The certification is from the manufacturer or his testing agency. Some manufacturers consistently produce nearly perfect products; others make inferior ladders, which are dangerous. Rejecting flawed products requires careful inspection. A certification is as good as the manufacturer's quality control program on a given day.
In the past, each worker has had a relationship with his tools. In many cases, the apprentice's first job was to build his tool box, then his ladder. For hundreds of years, workers made their own ladders and kept them repaired. Many lasted generations.
Modern ladders are mass-produced items with specifications limiting how they can be used. New laws and consensus standards apply to the exposing employer, and to the controlling employer on each work site. Employers have greater responsibilities. Among those, is the duty to inspect the job site where your employees will work. You are required to assess fall hazards and create ways to prevent falls. A competent, trained person is required to provide your training.
Training and retraining is mandatory. All climber training will be carried out by a competent person who knows safe ladder practice and the proper way a ladder can be safely used in your production process. Training objectives are met by judging the skills a person should have at the end of the training, and the way both student and teacher demonstrate knowledge of the subject.
In many plant settings, the use of a ladder is frequent and systematic. It is necessary to add anchor points to hold the ladder in place, or for attaching fall protection restraints. A competent person must be able to recognize the hazard and apply the correct solution.
Note: This work was originally published by the American
Society of Safety Engineers. The graphic used in this article is not intended to be an
example of safe ladder usage.
1. Schroeder, A.H., and Hastings, H.F., Montezuma Castle, Division of Publications, U.S. Department of the Interior, Washington, D.C. 1954.
2. C.S. White, and I.G. Bowen, Comparative Effects Data of Biological Interest, Lovelace Foundation for Medical Education and Research, Albuquerque, N.M. Apr. 1959.
3. Note that single beam ladders are illegal in the United States.
4. CPSC Fact Sheet #56, Dec. 1982.
5. Census of Fatal Occupational Injuries, Bureau of Labor Statistics. ftp://stats.bls.gov/pub/news.org/gov/gof1.text, May 1996.
6. FR V. 55, No. 69, April 10, 1990, at 13361.
7. 29 CFR 1910.25
8. OSHA Interpretation; Ladders, 12/06/91.
9. OSHA Interpretation: Ladders-PPE, December, 6, 1991.
10. Federal Register, April 10, 1990.
11. 29 CFR 1910.132, effective July 6, 1994.
12. OSHA Field Inspection Reference Manual, Section 3-30.
13. 29 CFR 1926.16 (d)
14. Heinrich, H.W., Peterson, Dan, Roos, Nestor. Industrial Accident Prevention. McGraw-Hill, New York, 1980.
15. 29 CFR 1926.1060(a)(1)
16. Fox, Arent, Deceptive Advertising and Labeling of extension ladders, www.webcom.com/_lewrose/trr/ladders.html, May 1996.
17. 55 FR 46791, Nov. 14, 1990.