OSHA Quiz: Can a fixed ladder be used as a second exit?

by Dwayne Towles

Scenario: You are the corporate safety specialist for a large organization.  The bulk of your job is to do site safety audits of the operations owned by your employer. You are conducting a site visit and safety audit of a light manufacturing facility and you notice a raised supervisor’s office that looks down on the production floor.  There is a fixed metal stairway that leads from the production floor to the office.  Upon closer inspection, the stairway appears to be completely up to code and acceptable.  However, when you go around to the other side of the raised office, you notice a door that leads to a fixed industrial ladder.  You ask “why is this here?”, and you are told that a few years ago a local fire inspector required the company to install the door and ladder as a secondary exit for employees located in the raised office.

Question: While this may meet the local fire inspector’s expectations, is this arrangement considered compliant with OSHA regulations?

Answer:  There are several issues to be considered here.  The first question that must be answered is “is the fixed ladder acceptable as a second exit?”  According to OSHA 1910.37 (a) (3) “…. Stairs or a ramp must be provided where the exit route is not substantially level.”  The standard makes no reference to ladders.  Also, in an OSHA letter of interpretation dated November 27, 1978 to L.C. Nicholas, P.E., OSHA states “A fixed metal ladder meeting the design requirements of 29 CFR 1910.27 would not be acceptable for a second [exit route] (emergency exit).”

So, if the second exit is truly necessary it must be in the form of a stairway that meets building codes.

However, is a second exit necessary?  OSHA says in 1910.36(b)(3) “A single exit route. A single exit route is permitted where the number of employees, the size of the building, its occupancy, or the arrangement of the workplace is such that all employees would be able to evacuate safely during an emergency.”  There is a note to paragraph (b) that says for assistance in determining the number of exit routes necessary for your workplace, consult NFPA 101.

We won’t get into the minutia of the details here, but upon review of the NFPA 101 Life Safety Code 40.2.4.1.2, you determine that a single exit is allowable for this type of arrangement since only a small number of employees occupy the office at any given time and the travel distance to the fixed stairs is limited.

Some of you may be saying “Yes, but the fire inspector is the AHJ (Authority Having Jurisdiction) and if he says they have to have a second exit, then they must have a second exit.”  We won’t argue that point.  However, in this instance, there are grounds to challenge the requirement.  The important issue here is that while using a ladder as the second exit from this supervisor’s office may appease the fire inspector, you are opening yourself up to an OSHA citation since the exit cannot be in the form of a ladder.  It would be best served in the form of a fixed stairway that meets the applicable building codes.

This entry was posted in Emergency Action Plan, Ladders, OSHA Interpretations, Safety Quiz and tagged , , , , , , , , . Bookmark the permalink.

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