Requirements of Mobile Ladder Stand Platforms Used to Access CNC Machines

Scenario: A mobile ladder stand platform with steps will be constructed to access multiple CNC machine tables at a height of 40 inches measured from the floor.

Question 1: What are the rise height, tread depth, and width requirements of mobile ladder stand platform steps?

Response: The requirements for mobile ladder stand platforms are contained in 29 CFR § 1910.23(e), Mobile Ladder Stands and Mobile Ladder Stand Platforms in addition to requirements specified in paragraph (b) of this section which covers all ladders. Specifically, § 1910.23(e)(1)(i) requires that the mobile ladder stands and platforms have “a step width of at least 16 inches (41 cm).” Additionally, § 1910.23(e)(3)(i) requires the steps of mobile ladder stand platforms meet the requirements contained in § 1910.23(e)(2)(i) which states, “(s)teps are uniformly spaced and arranged, with a rise of not more than 10 inches (25 cm) and a depth of not less than 7 inches (18 cm). The slope of the step stringer to which the steps are attached must not be more than 60 degrees, measured from the horizontal.”

Question 2: Does the landing area need to be 30 inches in the direction of travel?

Response: No. The 30-inch requirement in the direction of travel applies only to the stairways covered under 29 CFR § 1910.25.

Question 3: Do mobile ladder stand platforms, measured 40 inches or less in height from the ground, require a mid-rail or a top rail?

Response: No. A top rail and a midrail are not required for mobile ladder stand platforms less than 4 feet in height from the ground. Handrails with a vertical height of at least 36 inches (91 cm) and midrails are required in the platform area of mobile ladder stand platforms with a platform height of 4 to 10 feet (1.2 m to 3 m). (§1910.23(e)(3)(ii)). All mobile ladder stand platforms with a platform height above 10 feet (3 m) are required to have guardrails1 and toeboards2 on the exposed sides and ends of the platform. (§1910.23(e)(3)(iii)).

Question 4: Does the top rail on a mobile ladder stand platform need to withstand 200lbs of force?

Response: Yes, § 1910.29(b)(3) provides guardrail systems must be “capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied in a downward or outward direction within 2 inches (5 cm) of the top edge, at any point along the top rail.”

Source: https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0

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