Ladder Safety

On occasion, certain employees at Dow Aero (“Company”) may be required to use a ladder to perform their job duties. As a result, the Company has developed the following Ladder Safety Program to be used by both management and employees for ensuring the safe use of ladders within their working environments. These include:

  • Provides selection guidelines for the type of ladder to be used;

  • Identifies general requirements to maintain safe use in an assortment of environments;

  • Institutes necessary inspection items and baseline processes; and

  • Establishes proper storage methods.

This program has been developed in an effort for the Company to maintain compliance with Occupational Safety and Health Administration (OSHA) Rule CFR 1910.23, along with other supporting rule(s). If discrepancies exist between this policy and OSHA regulation, the regulation shall govern and the Company's Environmental Health & Safety (EHS) department shall be notified immediately.

Ladder Selection

Selecting the appropriate size and type of ladder for every task is critical. Employees, along with any other individuals, needing to use a Company-owned ladder shall consider the following before each use:

  • Verify the ANSI Duty Rating label, which indicates the maximum safe loading capacity, is above the intended weight of the person and tools to be placed on the ladder.

    • If the label is missing, see the Inspection section below.

  • Confirm the ladder’s material is appropriate for the type of work being performed:

    • Fiberglass is electrically non-conductive, and is preferred for most uses.

    • Aluminum is strong and lightweight, but may not be used near electricity.

    • Wood is electrically non-conductive when dry, but can be more sensitive to extreme weather and is generally not recommended.

      • e.g. heat or moisture.

  • When working on something that is positioned on either side of a ladder, opt for a rolling ladder or an aerial lift (requires certification to operate) when possible.

Additionally, the following selection requirements exist dependent on the type of ladder used:

  • Stepladders:

    • Stepladders longer than twenty (20) feet are not approved for Company use.

  • Single and Extension Ladders:

    • Single ladders longer than thirty (30) feet are not approved for Company use.

    • Extension ladders longer than sixty (60) feet are not approved for Company use.

Anytime where elevated work involves moderate to heavy pushing, pulling, or lifting, the use of an aerial device (e.g. scissor-lift or boom-lift) is recommended. When a ladder must be used for such tasks, added fall protection measures may be necessary.

Safe Use

Location

  • Make sure that the path is clear and wide enough to move a ladder through. 

  • Avoid placing ladders where they can be accidentally struck or displace.

    • If necessary to work in an occupied work area or walkway, barricade the area with a highly visible safety zone.

      • e.g. caution tape, signs, etc.

    • Ladders shall not be placed in front of doorways, unless the door is locked, barricaded, marked, or guarded by another individual.

  • Never use metal ladders around exposed electrical equipment and wiring

    • Keep ladders and tools at least ten feet away from overhead lines at all times.

  • Avoid areas where mud or debris are present.

    • Either wait until mud can dry or clear the area from debris before using the ladder.

  • Avoid working on ladders in winds of twenty-five (25) miles per hour or greater.

Setup

  • Use safe handling techniques for the loads that are to be encountered.

  • Ensure that all tools and equipment are removed from a ladder before moving. 

  • Confirm there is enough clearance between the top of the ladder and the ceiling, lights, wiring or lines, etc.

  • Always use ladders on flat and sturdy surfaces.

    • Appropriately sized wooden boards may be used to level a ladder on uneven ground and provide better footing when on soft ground.

    • Never place ladders on boxes, barrels, or other unstable bases to increase height.

  • Setup ladders in accordance with the manufactures instructions:

    • For rolling ladders, typically:

      • Apply brakes or wheel locks; and/or

      • Tie to a rigid structure.

    • For stepladders, typically:

      • Open legs fully and ensure both spreader bars are locked into place.

      • Do not use a stepladder in a folded, leaning position unless permitted by manufacture instructions.

      • Do not use stepladders to support work platforms.

    • For single/extension ladders, typically:

      • Set the ladder base one (1) foot away from the appropriate upright surface for every four (4) feet of the ladder’s length.

        • e.g. a twenty (20) foot extension ladder shall have its base placed five (5) feet from the appropriate upright surface.

      • Top of the latter shall extend three (3) feet above the work area or vertical surface.

      • Secure the ladder at the top to prevent it from slipping sideways and/or at its base to prevent it from slipping outwards.

        • When not possible, have a person brace the ladder at the ground level (most suitable for ladders up to sixteen (16) feet tall).

  • Never adjust or move a ladder while a person is on it.

Climbing/Standing

  • Ensure that proper footwear is free of mud, grease, or other substances that could cause a slip or fall.

  • Face the ladder, while alternating both hands and feet when keeping three points of body contact with the ladder at all times

    • One foot set, plus two hands holding the ladder;

    • Two feet set, plus one hand holding the ladder; or

    • Two feet set, plus the waste or chest touches the ladder.

  • Do not climb or stand beyond the manufacture’s instruction:

    • For rolling ladders, do not climb higher than the top platform; climbing on platform railing is not permitted.

    • For stepladders, do not climb or stand on the top step or cap.

    • For single/extension ladders, do not climb or stand on the top four (4) rungs.

  • Stay centered and do not extend the middle of the body beyond either side of the rails.

    • Especially includes not standing with one foot on the ladder and the other on a different object, such as shelving

  • Do not carry tools or materials by hand(s) when climbing.

    • Carry items on a tool belt, raise or lower items by hand lines, or use other reasonable means that maintain safety.

  • Never climb the bracing located on the backside of stepladders.

  • Only one person shall be on a ladder at a time.

Inspection

Prior to each use, inspect the ladder for the following conditions:

  • ANSI Duty Rating label present;

  • Free of cracks, splits, corrosion, broken or missing parts, along with protruding nails, screws, and splinters;

  • Steps/rungs free of oil or grease;

  • Steps/rungs firmly attached to side rails;

  • Safety feet/base and other hardware are in good condition;

  • Movable parts operate smoothly, without binding or excessive flexibility;

  • Properly functioning wheels and brakes (for rolling ladders); and

  • Ropes are in good condition (for extension ladders).

If discovered that a ladder is damaged, an employee shall not use and immediately remove it from service. The ladder shall be marked as “Damaged, Do Not Use” with either a tag, label, tape, or paper before employee leaves the work area where the ladder is stored. A manager or supervisor, department lead, or the Company's Environmental Health & Safety (EHS) department should be notified of a damaged ladder promptly. Temporary fixes or non-professional repairs made to any ladder is NOT PERMITTED.

Knowledgable, authorized personnel shall be responsible for determining whether a ladder is to be repaired or replaced. If a repair is determined, the ladder shall be fixed to meet manufacture specifications, with the repair being conducted by a trained professional. If determined that a ladder is to be replaced, the damaged ladder shall be immediately disposed of as appropriate to the location’s waste management provider’s requirements, if any exist.

Storage

All ladders are to be stored within an area that is sheltered from direct sunlight and moisture. Stepladders, along with single and extension ladders, that have a height greater than four (4) feet shall be securely fastened in a horizontal position, with supports added to prevent sagging as needed. Rolling ladder brakes or wheel locks shall be engaged to prevent movement.



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