OSHA Issues Clarification on the Guarding of Access Openings to Fixed Ladders
Do you think the ladder access point to this platform meets the OSHA standard for guarding?
OSHA’s general industry standard dealing with walking and working surfaces 1910.23(c) “Protection of open-sided floors, platforms, and runways.” Section (1) states the following: 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 an entrance to a ramp, stairway, or fixed ladder.
If you just read that section of the standard it would be reasonable to think you must have protection around all open sides of this platform except the entry point where there are stairs, ramps, or fixed ladders.
However, a recent memo written by Richard Fairfax, Director of OSHA Enforcement has a different take on this issue.
In his letter Mr. Fairfax states that the governing requirement for the guarding of ladderway floor openings and platforms is not in paragraph 1910.23 (c) but rather in paragraph 1910.23(a)(2): that states: “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.”
Mr. Fairfax goes on to state: “This paragraph applies to ladders that extend to another working surface, even if the ladder attaches to the edge of the working surface or the platform, since the opening at the ladder access point is also a floor opening. The ladders states the passage through the railing must be protected by a swinging gate or offset so that a person cannot walk directly into the opening.”
OSHA believes the intent of the exemption in paragraph (c) was to allow other than a standard, fixed, guardrail at the entrance to a fixed ladder.
Simply put, if you have a fixed ladder access to a floor or platform four feet or more above the adjacent floor or ground level, whether it is through an opening in the platform or along the edge, the access point to that floor or platform must be guarded by either an acceptable swing gate or a railing offset so the person cannot walk directly into that opening.
