Background: Multiple sections of off-set ladders are being designed to be installed on the outside of a grain silo that is 80 feet or more in height. Rest platforms will be installed at each off-set and will be provided with guardrail systems to meet OSHA’s requirements. The rest platforms measure 3 feet by 3 feet in area. Some of the ladder sections are less than 24 feet in length.
Question 1: Does each section of ladder above 24 feet from the ground require a ladder safety system or is the 24-foot height measured from rest platform to rest platform?
Background: Under 29 CFR 1910.23(a)(1), there is an exception for ladders used in emergency operations such as firefighting, rescue, and tactical law enforcement operations, or training for these operations. The ladders described in question #1 are only in place for emergency escape from the roof level of the structure should there be an emergency and personnel are on the roof at the time of the emergency. An elevator is normally used to access the roof of the structure.
Question 2: If the access point from the roof and ground levels to the ladder were clearly marked to indicate for emergency use, would the exception apply in this situation as it relates to installation of ladder safety system?