Cal/OSHA Adopts New Rules for Portable Ladders by: Tim Bormann, CIH, CAC
May 26, 2011
On January 7, 2011, Cal/OSHA promulgated several changes to the portable ladder standards, including step ladders. The new requirements are a major change from "business as usual" with respect to ladder use. Falls remain the most common cause of workplace fatalities and falls from ladders rank second only to falls from roofs. All of the requirements for portable ladders from both the General Industry Safety Orders (GISO) and Construction Safety Orders (CSO) have now been consolidated into one section, 8 CCR 3276, thus repealing or renaming all of the prior GISO portable ladder safety orders. Though Section 1675 of the CSO still exits, it essentially refers to compliance with the subsections of §3276. Section 3276 now includes requirements for design and construction of portable ladders based on American National Standard Institute (ANSI) Standards and adds requirements for selection, care and use. The design and construction requirements differ based on whether the ladder was placed in service before or after January 7, 2011.
One of the new requirements of Section 3276 is that before an employee uses a portable ladder, the employee and the employee's supervisor must be provided with training in the safe use of ladders. The training may be provided as part of the employer's Injury and Illness Prevention Program (IIPP) and must include several topics that are specified in the proposed standard, including:
Importance of using ladders safely including frequency and severity of injuries related to falls from ladders
Maintenance and inspection
Erecting ladders (support, securing and angle of inclination)
Climbing and working on ladders
Factors contributing to falls
Another major requirement is that ladders be inspected by a "qualified" person, both "frequently" and after any occurrence that could affect their safe use. Though "frequently" is not defined in the standard, we recommend the employer designate a time frame (e.g., weekly) and document the inspections as one would document an IIPP inspection. When setting the timetable for inspections, consider frequency of use, how the ladder was used and the environment in which it was used. Note that the proposed wording that inspections are done prior to the "start of the work shift" was removed from the final version of the standard. It remains to be seen how "frequently" will be interpreted.
A "Qualified Person" is generally defined by Cal/OHSA as a person designated by the employer who by reason of his training and experience has demonstrated the ability to safely perform his duties and, where required, is properly licensed in accordance with federal, state, or local laws and regulations. For the purpose of ladder inspections, we believe that any worker who demonstrates competency with the safe use of ladders can conduct these inspections (i.e., is "qualified"). If you have any questions regarding the new Cal/OSHA rules on portable ladders and the required training, call us. We have been conducting training on safe ladder use for many years and can help you in complying with this requirement.