Ladder Compliance with New OSHA Requirements

John Hill Industrial Hygiene

EFCOG Industrial Hygiene & Safety Task Group Meeting October 24, 2017

Walking Working Surface Final Rule

• On November 17, 2016 OSHA issued the updated Walking Working Surfaces Standard Subpart D

• This affected 29 CFR 1910.21 – 30

• Updated standards for fixed ladders, stairways, handrails, guardrails, training, etc.

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Walking Working Surface Final Rule

• SRNS conducted a site wide assessment of all facilities except those scheduled to be D&D or shutdown.

• Primary compliance issue at SRS is fixed ladders.

• Safety Engineers walked down all fixed ladders

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Distance from Rung to Nearest Interference is at Least 7 Inches

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Number of Ladders Complies

Gap Behind Rung >=7 In. Does Not Comply

Gap Behind Rung <7 In. % Non-compliance

418 259 159 38%

Distance from Rung to Nearest Interference is at Least 7 Inches

Interference Complies with OSHA D-3 Chart

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Number of Ladders Complies with D-3

Does Not Comply with D-3

% Non-compliance

159 58 101 64%

Interference Complies with OSHA D-3 Chart

Distance between Side Rails is 16 Inches or Greater

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Number of Ladders Complies

Rails >=16 inches Does Not Comply Rails <16 inches

% Non-compliance

418 415 3 1%

Distance between Side Rails is 16 Inches or Greater

Distance Between Grab Rails is at Least 24 Inches

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Number of Ladders Complies

Grab Rails >=24 inches Does Not Comply

Grab Rails <24 inches % Non-compliance

418 101 317 76%

Distance Between Grab Rails is at Least 24 Inches

Distance Between Centerline of Rung and Nearest Side Interference is at Least 15 in.

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Number of Ladders Complies

>=15 inches Does Not Comply

<15 inches % Non-compliance

418 404 14 3%

Distance Between Centerline of Rung and Nearest Side Interference is at Least 15 Inches

Distance Between Top Rail and Landing/Platform is 7 to 12 Inches

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Number of Ladders Complies

7 to 12 inches Does Not Comply < 7 or > 12 inches

% Non-compliance

418 61 357 85%

Distance Between Top Rail and Landing / Platform is 7 to 12 Inches

Has Self-Closing Gate

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Number of Ladders Complies

Has Self-Closing Gate Does Not Comply

No Self-Closing Gate % Non-compliance

418 32 386 92%

Has Self-Closing Gate

Headroom Between Ladder and Interference is 24 Inches or Greater

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Number of Ladders >24 Feet

Complies >24 inches

Does Not Comply <24 inches

% Non-compliance

428 394 24 6%

Headroom Between Ladder and Interference is 24 Inches or Greater

Ladders Taller Than 24 Feet with Safety Arrest System (20 Years to Comply)

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Number of Ladders >24 Feet

Complies >24 ft. with Safety Arrest

System

Does Not Comply >24 ft. without Safety

Arrest System

% Non-compliance

34 0 34 100%

Ladders Taller Than 24 Feet with Ladder with Safety Arrest System (20 Years to Comply)

Path Forward After Assessment

• Conduct further assessment to determine: – How often is the ladder used? – Is there any other hazard from using the ladder (must the worker be in additional PPE

such as supplied air respirator) • Develop a variance request to allow continued use with the existing designs • Fix some of the ladders (add self-closing gates) • Develop a time table as to which ones should be repaired and a schedule • Update the cost estimate for repairs. • Further issues to consider

– Interferences (conduit, water lines, etc.) – Hazards encountered to perform the repairs

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