Guarding access openings to fixed ladders

September 29, 2009

MEMORANDUM FOR:
REGIONAL ADMINISTRATORS
FROM:
RICHARD E. FAIRFAX, DIRECTOR

DIRECTORATE OF ENFORCEMENT PROGRAMS
SUBJECT:
Guarding of Access Openings to Fixed Ladders

The purpose of this memorandum is to clarify the requirements for guarding access openings to fixed ladders. Differences in the regulatory text between paragraphs 1910.23(a)(2) and 1910.23(c)(1) and silence on this issue in paragraph 1910.23(c)(2) and in the fixed ladder standard at 1910.27 have led to some confusion.

Openings on platforms are regulated by different paragraphs of §1910.23. Paragraph §1910.23(a) covers floor openings, including access openings at the edge of a platform. Paragraph §1910.23(b) covers wall openings and wall holes. Paragraph §1910.23(c) covers the edges of open-sided floors and platforms, but not the access openings at the edge of the platform or through the floor.

The governing requirement for the guarding of ladderway floor openings and platforms is paragraph 1910.23(a)(2):

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.

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. It also applies to floor openings in runways and catwalks. All ladderway floor openings or platforms must be protected by a standard railing except at the entrance to the opening. The passage through the railing, however, must be protected by a swinging gate or offset so that a person cannot walk directly into the opening.

Paragraph §1910.23(c)(1) requires a standard railing on all open-sided floors or platforms 4 feet or more above floor or ground level, except at entrances to ramps, stairways, or fixed ladders. It describes where a standard railing is required and includes an exception for the entrance to fixed ladders. This paragraph does not, however, exempt the passage through the railing for platforms from being protected by a gate or offset as required in paragraph 1910.23(a)(2). The intent of the exemption in paragraph (c) was to allow other than a standard, fixed, guardrail at the entrance to a fixed ladder. Required protection for the access openings on runways and catwalks are also included in this paragraph.

Unguarded ladderway floor openings and unguarded ladderway entrances on all surfaces should be cited under section 1910.23(a)(2).

If you need any additional information or clarification on this memorandum, please contact the Office of General Industry Enforcement at (202) 693-1850.