OSHA Question of the Month: February

Is Fall protection Required While Working from a Portable Stepladder?

Step Ladder

Scenario:  You are the safety director for a construction company. You have a worker who must perform a job from a 12 foot stepladder.  He needs to spend quite a bit of time on the ladder with his feet about 8 feet off the ground, but will not be standing on the top or top step of the ladder.  Your boss sees the activity while visiting the site.  He asks you if what is observed is a violation of the OSHA standard and references Subpart M that states in 1926.501(b)(1) “Unprotected sides and edges.” Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.

Question: Is fall protection required while working from a portable stepladder?

Answer: In 29 CFR Part 1926 Subpart M (Fall protection), Section 1926.500(a)(2)(vii) provides: Requirements relating to fall protection for employees working on stairways and ladders are provided in Subpart X .

There is no provision in Subpart X that requires fall protection for an employee while working from a portable stepladder no matter the height or length of time.