Subpart C
Under 1918.23(a) Jacob's ladders must be either the double-rung type or the flat-tread type. The standard requires these specific ladder types and does not permit single-rung or other types in place of the double-rung or flat-tread design (1918.23(a)).
Yes. Jacob's ladders must be well maintained and properly secured under 1918.23(a). The standard places responsibility on the employer to keep the ladder in good working condition and make sure it is secured so it can be used safely (1918.23(a)).
No. 1918.23(b) requires that a Jacob's ladder either hang without slack from its lashings or be pulled up entirely. Practically, that means you must tension the ladder so it does not sag during use or stow it up out of the way when it is not a taut means of access (1918.23(b)).
Yes. When a Jacob's ladder is used as the means of access to a barge being worked, spacers (bumpers) must be hung between the vessel, barge, or other structure to which the barge is tied alongside, or other equally effective means must be provided to prevent damage to the bottom rungs of the ladder (1918.23(c)).
Employers must provide suitable protection when a Jacob's ladder is being used so that there is a danger of an employee falling or being crushed between the vessel, barge, or other structure (pier) (1918.23(d)). "Suitable protection" is left to the employer's judgment based on the hazard; examples commonly used in the industry include guardrails, safety lines or lifelines, attendants to control the ladder use, or other measures that prevent falls or crushing. Employers should select measures that effectively eliminate the risk to employees.
Yes. 1918.23(c) allows "other equally effective means" in place of spacers (bumpers) to prevent damage to the bottom rungs of the ladder. That means as long as an alternative (for example, suitable fenders, bumpers of appropriate size, or an engineered guard) provides the same level of protection to the ladder rungs, it may be acceptable; the employer must ensure the chosen method is truly equally effective (1918.23(c)).
Pulled up entirely means the ladder is stowed so it is not hanging or available as a slack access—i.e., it is lifted clear of the water and out of use. The standard requires the ladder either to hang without slack or to be stowed so it is not dangling; employers should secure the ladder in the pulled-up position so it cannot swing or create a hazard (1918.23(b)).
No. 1918.23(a) requires Jacob's ladders be properly secured but does not prescribe a specific method for securing them. That leaves the employer responsible for choosing a secure means of attachment appropriate to the vessel and conditions and for ensuring that method keeps the ladder safe to use (1918.23(a)).
The standard requires Jacob's ladders be "well maintained," but it does not set a specific inspection interval. Employers are responsible for maintaining ladders in safe condition and should establish inspection and maintenance schedules appropriate to the ladder's use, environment, and wear patterns. Because 1918.23(a) leaves maintenance performance to the employer, employers should document inspections and repairs as part of their safety program (1918.23(a)).
Suitable protection must prevent the fall or crushing hazard; the standard does not list required devices but requires protection when the danger exists. Practical examples employers commonly use include installing temporary guardrails, using lifelines or safety harness systems with trained attendants, placing fenders or bumpers to limit vessel movement, or stationing a lookout or attendant to control ladder use and vessel movement. Choose measures that actually stop the fall/crush hazard and document why they are effective under the conditions present (1918.23(d)).
No. 1918.23(a) specifically requires Jacob's ladders to be of the double-rung or flat-tread type, so single-rung designs that do not meet that description are not acceptable as Jacob's ladders under this standard (1918.23(a)).
When a Jacob's ladder is used as access and the barge is tied alongside another vessel or structure, spacers (bumpers) must be hung between the vessel, barge, or other structure to which the barge is tied alongside to prevent damage to the ladder's bottom rungs (1918.23(c)). The spacers should be positioned so movement between the two hulls or structures will not crush or damage the ladder rungs.
The employer is responsible for recognizing the hazard and providing the protection required by 1918.23(d). The regulation does not assign the decision to a specific job title; it places the duty on the employer to assess conditions where a ladder could expose an employee to falling or crushing and to provide suitable protection (1918.23(d)). If there is uncertainty about which measures are effective, employers should consult qualified safety personnel or marine engineers and document the chosen protections.
The text of 1918.23 does not explicitly require training for ladder users, but employers must make sure ladders are safe and that employees are protected when hazards exist. Therefore, employers should provide training or instruction as needed so employees can use the ladder safely and recognize hazards; other OSHA standards or the employer's general safety responsibilities may also require training depending on the operation (1918.23(a)). For guidance on how OSHA applies different standards depending on workplace circumstances, see the interpretation about standards' applicability (Applicability of OSHA standards).