Understanding OSHA:
Ladder Use
The Occupational Safety and Health Administration (OSHA) imposes the following
requirements, among others, on construction employers pursuant to 29 C.F.R. § 1926.1053:
“Rungs, cleats, and steps of portable ladders . . . and fixed ladders
(including individual-rung/step ladders) shall be spaced not less than 10
inches (25 cm) apart, nor more than 14 inches (36 cm) apart, as measured
between center lines of the rungs, cleats and steps.
“Each employee shall use at least one hand to grasp the ladder when
progressing up and/or down the ladder.
“An employee shall not carry any object or load that could cause the
employee to lose balance and fall.”
Because ladder use is an important part of roofing activities, it is imperative all roofing
contractors know and understand OSHA’s standard regarding proper ladder use. Although the
ladder-use standard has many requirements, the three requirements set forth above are some of
the most common standards violated by roofing contractors’ employees.
The first two requirements leave little room for interpretation. All roofing contractors should
ensure ladders at their construction sites comply with the requirement that the rungs, cleats and
steps of portable and fixed ladders must be spaced not less than 10 inches, nor more than 14
inches, apart as measured between the center lines of the rungs, cleat and steps. Roofing
contractors also must ensure their employees are properly using ladders by using at least one
hand to grasp a ladder when progressing up and/or down.
The third requirement does leave some room for interpretation. Although OSHA believes small
items such as hammers, pliers, measuring tapes, nails, paint brushes and similar items should be
carried in pouches, holsters or belt loops, the standard’s language does not preclude an employee
from carrying such items while climbing a ladder so long as the items do not impede an
employee’s ability to maintain full control while climbing or descending a ladder.
Regarding OSHA’s fall-protection requirements and how they apply to fixed ladder use and
portable ladder use, OSHA’s ladder standard also provides fall protection must be provided
whenever the length of the climb on a fixed ladder equals or exceeds 24 feet. Also, even if the
length of climb is less than 24 feet, cages, wells, ladder safety devices or self-retracting lifelines
must be provided when the top of the fixed ladder is greater than 24 feet above lower levels.
Interestingly, OSHA does not require fall protection for employees climbing or working on
portable ladders. Neither the ladder standard nor the fall-protection standard require fall
protection for workers while working on portable ladders, and there are no OSHA construction
standards that specifically prohibit an employee from working from a portable stepladder.
However, OSHA does take a position that the use of a portable ladder still must comply with the
requirement not to load the ladder beyond the maximum intended load for which it was built nor
beyond the manufacturer’s rated capacity. Portable ladders also must only be used for the
purpose for which they were designed, and the top or top step of a stepladder cannot be used as a
step.