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OSHA 1915.72

Ladder requirements in shipyards

Subpart E

21 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.72(a)(1), what should I do if I find a ladder with a broken rung, split side rail, or other defect in a shipyard?

You must immediately remove the defective ladder from service and not use it until repaired or replaced. Under 1915.72(a)(1), ladders with broken or missing rungs or steps, broken or split side rails, or other faulty construction are prohibited, and metal ladders must be inspected for corrosion inside open-end hollow rungs.

  • Tag or physically block the ladder so it cannot be used and follow your employer’s procedures for repair or disposal.
  • Keep records or a log of withdrawn ladders if your site needs an audit trail of inspections and repairs.
  • A competent person may be assigned to recognize these hazards and specify corrective action; see OSHA’s guidance on competent person responsibilities in shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

Under 1915.72(a)(2), what are the requirements when ladder sections are spliced?

When ladder sections are spliced, the ends must be butted together and at least two cleats must be securely nailed or bolted to each rail, and the combined cross-sectional area of those cleats must be at least equal to the cross-sectional area of the side rail. This is required by 1915.72(a)(2).

  • The splice must have abutted ends (no gaps).
  • Use at least two cleats per rail; fasten them securely by nails, bolts, or equivalent fasteners.
  • Ensure the cleats’ combined cross-sectional area is not less than the side rail’s cross-section so the splice does not weaken the ladder.

Under 1915.72(a)(3), how must portable ladders be secured while in use in shipyard work?

Portable ladders must be lashed, blocked, or otherwise secured so they cannot be displaced. 1915.72(a)(3) requires preventing ladder movement.

  • Tie or lash the ladder at the top to a secure anchorage, place cleats or wedges at the base to stop slipping, or use a ladder stabilizer, depending on the situation.
  • For ladders used as access to elevated work, secure both top and bottom when possible to prevent shifting while employees climb.

Under 1915.72(a), how high must ladder side rails extend above the level they provide access to, and what if that is not practical?

Side rails of ladders used for access must extend at least 36 inches above the level being accessed, and if that is not practical a secure grab rail must be provided. See 1915.72(a).

  • If you cannot extend the rails 36 inches, install a grab rail that gives a secure handhold for the employee moving on or off the ladder.
  • Ensure the grab rail is strong enough and placed so workers can grasp it comfortably during transition.

Under 1915.72(a)(4) and 1915.5, what standards apply to manufactured portable metal ladders provided in shipyards?

Manufactured portable metal ladders must have strength equivalent to wood ladders and must comply with ANSI A14.2-1972 as incorporated by reference in 1915.72(a)(4) and 1915.5.

  • If you supply metal ladders to employees, verify they were manufactured to the ANSI A14.2-1972 requirements (see the incorporation via 1915.5).
  • Even when ANSI covers detailed design, you must still inspect and maintain metal ladders per 1915.72(a)(1).

Under 1915.72(a)(5), can portable metal ladders be used near electrical conductors or for arc welding in shipyard work?

No; portable metal ladders must not be used near electrical conductors nor for electric arc welding operations. This prohibition is stated in 1915.72(a)(5).

  • Use nonconductive ladders (e.g., wooden or fiberglass) when workers will be exposed to live electrical parts or when welding arcs or related operations are present.
  • If a metal ladder must be in the area, remove or isolate electrical hazards and follow lockout/tagout and welding safety rules as applicable.

Under 1915.72(a)(6) and 1915.5, what standard applies to manufactured portable wood ladders provided to employees in shipyards?

Manufactured portable wood ladders provided by the employer must meet ANSI A14.1-1975, as incorporated by reference in 1915.72(a)(6) and 1915.5.

  • Confirm supplier documentation or markings showing conformance to ANSI A14.1-1975 for purchased wooden ladders.
  • Regardless of ANSI compliance, perform routine inspections per 1915.72(a)(1).

Under 1915.72(b)(1)–(b)(3), what wood and quality requirements apply to portable wood cleated ladders up to 30 feet?

Wood side rails for ladders up to 30 feet must be made of West Coast hemlock, Eastern spruce, Sitka spruce, or wood of equivalent strength, be seasoned and straight-grained, and free of defects; knots must be sound and hard. See 1915.72(b)(1)–(b)(3).

  • Do not use low-density woods.
  • Rails must be dressed on all sides and kept free of splinters as required by 1915.72(b)(2).
  • Ensure knots are sound and hard per 1915.72(b)(3).

Under 1915.72(b)(4), what are the limits for pitch pockets in wood ladder side rails?

Pitch pockets are allowed only if they do not exceed 1/8 inch in width, 2 inches in length, and 1/2 inch in depth, and no more than one such pocket is permitted in each 4 feet of rail length. See 1915.72(b)(4).

  • Inspect rails for pitch pockets and remove ladders with pockets larger or more frequent than permitted.

Under 1915.72(b)(5), how wide must the base of a portable wood ladder be between side rails?

For ladders 10 feet or less, the width between side rails at the base must be at least 11½ inches; for longer ladders increase the width by at least 1/4 inch for every additional 2 feet of length, per 1915.72(b)(5).

  • Example: a 20-foot ladder needs a base width of at least 11½ inches + (10 ft / 2 ft × 1/4 in) = at least 12¾ inches.

Under 1915.72(b)(6), what minimum cross-sectional dimensions are required for side rails of portable wood ladders up to 30 feet?

Side rails must be at least 1⅝ × 3⅝ inches in cross section for portable wood cleated ladders up to 30 feet, as stated in 1915.72(b)(6).

  • Confirm actual rail dimensions meet or exceed these minimums before placing ladders into service.

Under 1915.72(b)(7)–(b)(8), what are the requirements for cleats (rungs) on wood ladders up to 30 feet?

Cleats must be the same material as the side rails, straight-grained and knot-free; they must be mortised into the rail edges or use filler blocks, fastened with three 10d common wire nails or equivalent, spaced uniformly not more than 12 inches apart; cleats 20 inches or less must be at least 25/32 × 3 inches in cross section. See 1915.72(b)(7) and 1915.72(b)(8).

  • Check for three 10d nails or equivalent fasteners on each cleat; replace cleats if fasteners are missing or loose.
  • Maintain cleat spacing at 12 inches or less for safe footing.

Under 1915.72(c)(1)(i)–(iii), how do requirements change for portable wood cleated ladders 30–60 feet in length?

Ladders 30 to 60 feet long generally follow the paragraph (b) specifications but must use rails of not less than 2 × 6 inch lumber, cleats of not less than 1 × 4 inch lumber, and cleats fastened to each rail with five 10d common wire nails or equivalent fasteners, as required by 1915.72(c)(1)(i)–(iii).

  • For very long ladders, ensure lumber sizes and fastener counts meet these increased strength requirements.
  • Inspect extra-long ladders carefully for bending, warping, and secure cleat fastening.

Who can determine whether a ladder is safe to return to service after defects are found in a shipyard under Part 1915?

A competent person designated by the employer may evaluate ladder condition and specify the necessary protection or corrective action, including whether to repair or discard a ladder. OSHA’s shipyard competent person definition and responsibilities are described in the Competent person requirements in shipyards letter of interpretation and in Part 1915 definitions.

  • The competent person must be capable of recognizing unsafe conditions and specifying protections as required in 29 CFR Part 1915.
  • Employers should document who is the competent person and their determination when ladders are withdrawn, repaired, or returned to service.

Under 1915.72, are employers allowed to use ladders that contain loose knots or knots on the narrow face of the rail?

No; the use of material containing loose knots is prohibited, knots must not appear on the narrow face of the rail, and knots in the side face must be no larger than 1/2 inch in diameter and meet placement limits, per 1915.72(b).

  • Inspect rails for loose or improperly located knots and remove ladders that fail these knot restrictions.

Under 1915.72(b)(7), how must cleats be fastened to side rails and how far apart can cleats be spaced?

Cleats must be mortised into rail edges or use filler blocks, secured to each rail with three 10d common wire nails or equivalent through bolts or fasteners, and cleats must be uniformly spaced not more than 12 inches apart, as required by 1915.72(b)(7).

  • Verify each cleat has the required fasteners and replace missing or damaged fasteners before use.
  • Maintain consistent tread spacing to ensure predictable footing.

Under 1915.72(b)(8), what is the minimum cross section for cleats 20 inches or less in length?

Cleats 20 inches or less in length must be at least 25/32 × 3 inches in cross section, per 1915.72(b)(8).

  • Use cleats that meet or exceed these dimensions to ensure adequate strength and footing.

If my workplace uses both wooden and metal portable ladders, how do I ensure compliance with Part 1915 ladder rules?

You must follow the material-specific construction and use requirements in 1915.72 — manufactured metal ladders must meet ANSI A14.2 per 1915.72(a)(4) and metal ladders must not be used near electrical conductors per 1915.72(a)(5), while wood ladders must meet the construction details in 1915.72(b)–(c).

  • Keep separate inspection checklists for wood and metal ladders to verify species, dimensions, cleat fastenings, corrosion checks, and ANSI conformance.
  • Train workers to select the appropriate ladder type for the task (e.g., avoid metal ladders around electrical hazards).

Under 1915.72, is it acceptable to repair a damaged ladder splice by adding a single cleat to each rail instead of two?

No; repaired splices must have not fewer than two cleats securely nailed or bolted to each rail, and the combined cross-sectional area of those cleats must be at least equal to the side rail, as required by 1915.72(a)(2).

  • Using only one cleat per rail would not meet the minimum splice requirement and could make the ladder unsafe.

Under 1915.72, how often should metal ladders be inspected for interior corrosion of hollow rungs?

While 1915.72(a)(1) requires inspection of metal ladders to include checking for corrosion inside open-end hollow rungs, the standard does not set a specific frequency; inspections should be conducted routinely and whenever defects are suspected.

  • Conduct regular pre-use visual inspections and periodic, documented inspections by a competent person; inspect hollow rungs internally when possible or before putting a ladder into service.
  • Withdraw and tag ladders showing internal corrosion until evaluated and repaired or replaced.

Under 1915.72, can an employer accept ANSI-labeled ladders from employees instead of providing ladders under the employer’s program?

Employers must provide ladders that comply with Part 1915 requirements; when manufactured ladders are used, the employer should ensure they meet the applicable ANSI standards incorporated by reference in 1915.72(a)(4) and (a)(6) and 1915.5.

  • Even if an employee brings a ladder labeled to ANSI, the employer remains responsible for ensuring it is suitable, in good condition, and not used near electrical hazards when prohibited.
  • Document acceptance policies and inspection results if employees supply equipment used on the job.