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Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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.
12071 Hamilton Avenue
Cincinnati, Ohio 45231

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




January 6, 1993

Dorothy L. Strunk
Acting Administrator
U.S. Department of Labor
OSHA
200 Constitution Ave. N.W.
Washington, D.C. 20210

Ms. Strunk,

Enclosed you will find correspondence between myself and Linda Anku, Regional Administrator of Region III. I am taking her suggestion and writing to the National Office for further determination, for nationwide use of this ladder system.

We are attempting to develop an alternative method of access to the top of a sheet pile. The other methods we describe in our first letter to Ms. Anku, are in use, but we are always looking for a safer and more productive and inexpensive means.

As stated in my original letter, we currently are not using this ladder for any purpose. If we were to begin to use this type of access system, we would comply with Region III's requests. What we need to know is, will this be an acceptable alternative for use in all states?

Your help in this matter will be greatly appreciated. I look forward to your response.

Sincerely,



Richard Marshall
Safety Director




December 1, 1992

Linda R. Anku
Regional Administrator
Gateway Bldg.,
Suite 2100
3535 Market Street
Philadelphia, PA 19104

Ms. Anku,

On November 23, 1992, Mr. John McFee and myself had a conversation about rope ladder access to the top of sheet piling during installation. There are several options available to a contractor to have an employee gain access to the top of the sheet pile.

The contractor may use a regular extension ladder, an aerial lift, or a personal platform to get the employee on top of the sheet pile. Each of these work, but they may not be the best and safest way to get to the top.

Several of our employees discussed using a rope ladder, similar to a Jacobs ladder used in Marine Operations (CFR 1926.605(b)(3)) Miller Equipment, a fall protection manufacturer, makes a ladder similar to a Jacobs ladder only with more refinements. I have enclosed a sketch of how we think this ladder could be used for our needs.

Since most climbs would cover a height of 20 to 40 feet, an independent life line could be attached to the top J-hook shackle. A harness, lanyard and rope grab could be worn by the employee for fall protection. A weight could be attached to the bottom of the line, in order to keep it taught.

We have not tried this system and don't intend to use it without some approval. We are looking for some professional advice and ideas however, to make this a workable alternative. We look forward to working with Mr. McFee in this matter.

Thank You



Richard Marshall
Safety Director




December 21, 1992

Richard Marshall
Safety Director
Richard Goettle Inc.
12071 Hamilton Avenue
Cincinnati, Ohio 45231

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


Archive Notice - OSHA Archive

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.


Standard Interpretations - Table of Contents Standard Interpretations - (Archived) Table of Contents