Rope ladder access to sheet pilings during construction

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

February 3, 1993

Mr. Richard Marshall
Safety Director
Richard Goettle Inc.
[Recipient address omitted]
Dear Mr. Marshall:

Your letter dated January 6, to Ms. Dorothy L. Strunk, former Acting Assistant Secretary of Labor, requesting an interpretation of Occupational Safety and Health Administration (OSHA) standards addressing the use of ladders has been forwarded to the Office of Construction and Maritime Compliance Assistance for response.

As you know, OSHA does not approve nor endorse products. The variable working conditions at jobsites and possible alterations or misapplication of an otherwise safe product could easily create a hazardous condition beyond the control of the manufacturer. However, we have reviewed the product data accompanying your letter and it appears that if the rope ladder is used to gain access to the top of sheet pilings during installation as described in your letter and if the safeguards outlined in Region III's December 21 correspondence to you are followed, the ladder would comply with OSHA requirements.

If we can be of any further assistance, please contact Roy Gurnham or Dale Cavanaugh of my staff at (202) 219-8136.

Sincerely,
Roger A. Clark
Director
Directorate of Compliance Programs

[Requester correspondence reproduced on OSHA page; omitted here. The regional OSHA interpretation follows.]

December 21, 1992

Richard Marshall
Safety Director
Richard Goettle Inc.
[Recipient address omitted]

Dear Mr. Marshall:

This letter is in response to your request for a determination as to whether a rope ladder, that is similar to a Jacobs ladder but has some additional features, can be used to gain access to the top of a sheet piling. The ladder has "stand offs" and is attached to the top of the sheet pile by shackles attached to "J" hooks. An employee could tie off to a life line attached to the "J" hook shackle.

The ladder, as described in your letter, can be used to gain access to the top of sheet piling during installation if certain conditions are met. However, please note, OSHA does not endorse or approve equipment. Therefore, although it has been determined that the ladder in question can be used, OSHA is not endorsing or approving such usage.

The referenced rope ladder can be used to gain access to the top of sheet piling during installation if all the following conditions are met:

1. The ladder shall be capable of supporting four times the maximum intended load without failure.

2. The rungs, cleats or steps of the ladder shall be uniformly spaced not less than 10 inches (25cm) apart nor more than 14 inches (36cm) apart, as measured along the ladder's side rails.

3. The minimum clear distance between the side rails of the ladder shall be eleven and one half inches (29 cm).

4. The components of the ladder shall be surfaced so as to prevent injury to an employee from punctures or lacerations, and to prevent snagging of clothing.

5. The employee climbing the ladder shall always wear a safety belt or body harness (preferably a body harness) connected to a rope grab that is attached to an independently rigged lifeline. The lifeline would have to be kept taut.

6. The ladder shall be equipped with and used with "stand offs".

7. The requirements, as applicable, set forth in OSHA Standards 29 CFR 1926.1051-1926.1053 shall be complied with.

The guidance contained in this letter is applicable only to Region III's jurisdictional area. If you plan to use the type of ladder in question outside of Region III you will need to contact the regional office that has jurisdiction, or you may write to our National Office for a determination that would be applicable nationwide.

In addition to the issue of the use of the rope ladder, we would like to address one other issue to insure there is no misunderstanding regarding the requirements of OSHA's standards as they relate to the use of personnel platforms. In your letter, a comment was made indicating that personnel platforms could be used to gain access to the top of sheet piles. If that comment was about the use of crane or derrick suspended personnel platforms such practices are prohibited except when the criteria set forth at 29 CFR 1926.550(g)(2) is met.

If you require any additional information regarding the preceding, please contact John McFee of my staff at (215) 596-1201.

Sincerely,
LINDA R. ANKU
Regional Administrator