SAFETY FOCUS
Pay Close Attention to CFR 1926.1053: This Safety Standard is Often Cited by OSHA Inspectors
By Sam Steel, NALP safety advisor
YEAR AFTER YEAR, INSPECTIONS INVOLVING UNSAFE LADDER use makes it to the top 10 list of most often cited workplace violations that are written up by OSHA inspectors. And, once the citation has been written, next comes the monetary fine for a serious violation. At just under $14,000 per violation, the unsafe practices that were documented can become monetarily expensive for landscape businesses.
One method for reducing unsafe ladder use and increasing your knowl- edge and understanding about OSHA’s ladder safety regulations is to use this model, referred to appropriately as L-A-D-D-E-R. If you follow each letter in order, your firm may be more likely to be in compliance with ladder safety regulations. So, let us begin.
L – LEARN about the OSHA ladder standard (CFR 1926.1053) online at
www.osha.gov. When you access the OSHA portable ladder standard, you will notice that there are twenty-two specific standards that are citable. These are CFR 1926.1053(b)(1) through (b)(22). Should your firm have a serious ladder incident that triggers an OSHA worksite visit, you could be cited under multiple standards during an inspection. For example, if the inspection finds that a “competent” person had not done a previously doc- umented ladder inspection, your notifi- cation letter would note 1926.1053(b) (15) as a violation. If the subject ladder were found to have damage or defi- ciencies that existed prior to the inci- dent and was not tagged “Do Not Use”, 1926.1053(b)(16) would be cited. And, if the ladder had been repaired and the repairs did not meet original design criteria, you could also be cited under 1926.1053(b)(18). These citations could carry recommended serious violation fines of over $50,000 (3 X $14,000).
L – LIST all ladder hazards that you can identify in the workplace. This is also known as the auditing phase that is so important in writing and enforc- ing workplace policies and finding the training resources you will adopt for your employees. These audited ladder hazards should be fully documented and become part of your written safety and health management program.
A – ACTIVATE a ladder safety policy for your firm. If ladders are a commonly used piece of equipment at your worksites or in your maintenance shop, employees should be aware of your written policies and sign-off on them during the hiring process.
A – APPOINT a ladder safety inspector from among your staff. This is the individual that OSHA refers to as the “competent person” within your organization who is knowledgeable about safe ladder design criteria and the OSHA portable ladder standard.
D – DEVELOP ladder safety train- ing for your employees. Several large ladder manufacturers have excellent ladder safety training resources that are available online. Your insurer may also have ladder safety materials or personnel who can aid with developing and presenting an effective ladder training program.
D – DELIVER ladder safety training for all workers. It is imperative that ladder safety training be presented before your employees are exposed to
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ladder use that could put them at risk. Once the training is completed, have all trained workers sign off on the training so that it is fully documented.
E – EVALUATE your ladder safety training initiatives to ensure their effectiveness. One evaluation tool is to use a pre- and post-test during the training. You should be able to monitor how much the workers knew about safe ladder use before and after their training. If post-testing shows little knowledge gain as a result of the train- ing, re-training may be required.
E – SET A GOOD EXAMPLE!
When demonstrating safe ladder use, always climb and work around ladders by following the OSHA portable ladder safety standards.
R – REPLACE AND/OR REPAIR damaged and dangerous ladders. If you decide to repair them, make sure the repairs restore them to their original design criteria. If your intentions are to replace the ladder, make sure the damaged ladder is clearly marked “Do Not Use” and placed in an inaccessible storage area.
R – REVIEW your firm’s ladder
safety policy at least annually. This would allow for newly contracted work (for example gutter cleaning, holiday house trimming, and arborist work) that your employees may be doing that requires an updated policy and training.
Use this ladder safety model to keep your firm compliant with OSHA’s important portable ladder standard. TLP
NALP SAFETY PROGRAM PARTNER:
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