Ladders In Trenches
1926.651(c)(2) Means of egress from trench excavations.
A stairway, ladder, ramp or other safe means of egress shall be located in trench excavations that are 4’
or more in depth so as to require no more than 25 feet of lateral travel for employees.
• The ladder must extend 3’ from the top of the trench
1926.1053(b)(1)
When portable ladders are used for access to an upper landing surface, the ladder side rails shall extend
at least 3 feet (.9 m) above the upper landing surface to which the ladder is used to gain access.
• The ladder must be secured
1926.1053(b)(5)(i)
Non-self-supporting ladders shall be used at an angle such that the horizontal distance from the top
support to the foot of the ladder is approximately one-quarter of the working length of the ladder (the
distance along the ladder between the foot and the top support).
1926.1053(b)(6)
Ladders shall be used only on stable and level surfaces unless secured to prevent accidental
displacement.
• The ladder must be in working condition
1926.1053(b)(15)
Ladders shall be inspected by a competent person for visible defects on a periodic basis and after any
occurrence that could affect their safe use.
1926.1053(b)(16)
Portable ladders with structural defects, such as, but not limited to, broken or missing rungs, cleats, or
steps, broken or split rails, corroded components, or other faulty or defective components, shall either
be immediately marked in a manner that readily identifies them as defective, or be tagged with "Do Not
Use" or similar language, and shall be withdrawn from service until repaired.
• Proper Use
1926.1053(b)(20)
When ascending or descending a ladder, the user shall face the ladder.
1926.1053(b)(21)
Each employee shall use at least one hand to grasp the ladder when progressing up and/or down the
ladder.
1926.1053(b)(22)
An employee shall not carry any object or load that could cause the employee to lose balance and fall.
Letter of Interpretation # 20071211-8130
Re: Removing ladders during trenching activities; compliance with 29 CFR 1926.651(c)(2)
Question: We have found that in certain circumstances, having a ladder in a trench box makes it difficult
to provide our employees with enough room to work safely while installing underground drain, sewer,
and water pipes. We would like to institute the following alternative procedure during those instances:
(1) Once the employees have used the ladder to enter the trench box, the ladder will be removed and
kept ready for use at the exit point just outside the box; (2) Two workers trained in the procedure will
remain at the exit point just outside the box so that they can immediately lower the ladder in the event
of an emergency or when the employees otherwise need to egress the trench; (3) The two workers
outside the trench would be in uninterrupted communication with the workers inside the trench for the
period during which the ladder has been removed.
A Job Hazard Analysis would be provided to all superintendents detailing the basic job steps, potential
hazards, and this procedure in the event the ladder is removed, which includes training for two workers
who will be responsible for removing the ladder, communicating with the worker(s) inside of the trench,
and inserting the ladder in case of an emergency. Would this be in compliance with 29 CFR 1926.651(c)
(2)?
Answer: Section 1926.651(c)(2) states:
Means of egress from trench excavations. A stairway, ladder, ramp or other safe means of egress shall
be located in trench excavations that are 4 feet (1.22 m) or more in depth so as to require no more
than 25 feet (7.62 m) of lateral travel for employees. [Italics in original, emphasis added]
Thus, §1926.651(c)(2) requires a safe means of egress to be located in trench excavations that are 4
feet (1.22 m) or more in depth. Please note that §1926.651(c)(2) does not exclusively require the use of
ladders during trenching activities; a "stairway, ramp, or other safe means of egress" may be utilized.
However, regardless of the means of egress employed, it must be available for use by the employees at
all times.
In an emergency situation, the system you describe would involve a delay between the occurrence of
the need, the recognition by the employees outside of the trench of that need, and the time it would
take to lower the ladder. Also, the complexity of such a system makes it inherently more susceptible
to failure than a simple requirement to have a ladder or similar means of egress in place in the trench.
Consequently, the system you describe would not be considered an "other safe means of egress" under
1926.651(c)(2).
You indicate in your question that maintaining a ladder in the restricted space within the trench box in
certain situations would create a greater hazard. However, in light of the necessity for immediate egress
in the event of an emergency, we are unaware of safety problems that would be caused by the presence
of the ladder that would pose a greater hazard than its absence.
Richard E. Fairfax, Acting Director
Directorate of Construction
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