In the past several years, I have had the pleasure of working on some fascinating start-ups. But the one thing they all have in common is that their ladders do not meet the new ladder standard, 1910.23. Ladders still have cages, not a fall arrest system, etc. The other thing that drives me crazy is that each facility had a lot of equipment on the roof, and operators had to access it multiple times per shift on “good days”. When things were not running as planned, they were up and down in these areas dozens of times a shift.
There is an often-overlooked OSHA requirement regarding access to these elevated positions:
1910.25(b)(7) Standard stairs are used to provide access from one walking-working surface to another when operations necessitate regular and routine travel between levels, including access to operating platforms for equipment.
The old Stair standard actually provided a frequency to help us understand when stairs vs ladders were needed: (emphasis by me)
Fixed stairs shall also be provided where access to elevations is daily or at each shift for such purposes as gauging, inspection, regular maintenance, etc., where such work may expose employees to acids, caustics, gases, or other harmful substances, or for which purposes the carrying of tools or equipment by hand is normally required. (It is not the intent of this section to preclude the use of fixed ladders for access to elevated tanks, towers, and similar structures, overhead traveling cranes, etc., where the use of fixed ladders is common practice.)
So the “intent” is/was clear… when workers have to access elevated surfaces, stairs are the required method. But man, you’d think I shot someone’s puppy when I bring this up in the engineering/code review of a design. It comes up again when we begin discussing “means of egress” from the elevated surface. But usually I am said to be an extremist and that “this design has been used for decades and no AHJ has ever said anything about access to and from the roof, even during an emergency”. So take it as you wish…
If there are hazardous materials on your roof and workers must be on the roof daily or at each shift, you need TWO (2) means of egress. ONE (1) of them can be a fixed ladder built to 1910.23, but the other must be a set of stairs that meets 1910.25.
For those curious as to what the International Building Code (IBC) requires:
1011.12 Stairway to roof. In buildings four or more stories above grade plane, one stairway shall extend to the roof surface unless the roof has a slope steeper than four units vertical in 12 units horizontal (33-percent slope).
Exception: Other than where required by Section 1011.12.1, in buildings without an occupied roof access to the roof from the top story shall be permitted to be by an alternating tread device, a ships ladder or a permanent ladder.
1011.12.1 Stairway to elevator equipment. Roofs and penthouses containing elevator equipment that must be accessed for maintenance are required to be accessed by a stairway.
1011.12.2 Roof access. Where a stairway is provided to a roof, access to the roof shall be provided through a penthouse complying with Section 1510.2.
Exception: In buildings without an occupied roof, access to the roof shall be permitted to be a roof hatch or trap door not less than 16 square feet (1.5 m2) in area and having a minimum dimension of 2 feet (610 mm).