Big Steps in Ladder Safety
We've been asking Cal-OSHA to simplify Title 8 regulations for years and our wish has finally come true. Regulations regarding the use of portable ladders, whether in construction (CSO) or general industry (GISO) has been consolidated into one easy-to-read Section - Section 3276 of Title 8. While there are still several regulations in both sections that revolve around the use of portable and fixed ladders; between January and March of 2012 various amendments and adoptions were made to consolidate and streamline the ladder regulations.
Many risk managers have remarked that there are new training requirements implemented as part of the March 9th, 2012 adoptions, the training requirements have been in effect since the January 2010 changes (prior to the March 9th updates). The current training matrix by Cal-OSHA does not address ladders, but was updated in August of 2006 and is sorely in need of an update which may be the cause of some risk manager's belief that the recent regulatory changes somehow implemented training requirements. That being said, if you are unfamiliar with the ladder training requirements, now is a good time to review the regulations - see bottom of post.
So, what did change? The recent set of changes implemented a reference from CSO Sections 1648 and 1675 to GISO Section 3276 thereby consolidating all of the regulations into one section. This is probably the single biggest change to the overall set of regulation and marks a great step forward in user friendliness. The impetus behind this change was simple - ladder hazards and incidents are basically the same - falling from a height, improper use, selection, training and the like. As noted above Title 8, Section 3276 is not the only section covering the use and selection of ladders, but it is now the primary.
The changes that were made include the definition and prohibition of a "single-rail ladder"; and the selection of ladders including those used with Jack Scaffolds. Both of these changes are reflected in the Subsections (b) and (d) of 3276.
So what should we do?
It's time to get familiar with the ladder changes. Start by reading the full text of each of these regulations. Review your training programs to ensure that they include ladder safety. There are several resources available that deal with ladder safety training and I am sure that there are many more to come such as TrainMyCrew and Safe Schools. Take a look at some innovative safety products such as Safe-T-Climb, which is a ladder stabilization device.
Generally speaking, ladder training under Title 8, Section 3276(f) should address the following:
(f) Employee Training. Before an employee uses a ladder, the employee shall be provided training in the safe use of ladders, unless the employer can demonstrate that the employee is already trained in ladder safety as required by this subsection. Supervisors of employees who routinely use ladders shall also be provided ladder safety training, unless the employer can demonstrate that the supervisor is already trained in ladder safety as required by this subsection. The training may be provided as part of the employer's Injury and Illness Prevention Program required by Section 3203. The training shall address the following topics, unless the employer can demonstrate a topic is not applicable to the safe use of ladders in the employer's workplace.
(1) Importance of using ladders safely, including: frequency and severity of injuries related to falls from ladders.
(2) Selection, including: types of ladders, proper length, maximum working loads, and electrical hazards.
(3) Maintenance, inspection, and removal of damaged ladders from service.
(4) Erecting ladders, including: footing support, top support, securing, and angle of inclination.
(5) Climbing and working on ladders, including: user's position and points of contact with the ladder.
(6) Factors contributing to falls, including: haste, sudden movement, lack of attention, footwear, and user's physical condition.
(7) Prohibited uses, including: uses other than designed, climbing on cross bracing, maximum lengths, and minimum overlap of extension ladder sections.