A description of the proposed changes are as follows:

1. TITLE 8:

CONSTRUCTION SAFETY ORDERS
Chapter 4, Subchapter 4, Sections 1637(n) and 1660(f)
GENERAL INDUSTRY SAFETY ORDERS
Subchapter 7, Sections 3277 through 3280
Update of ANSI References for Ladder-Type and
Needle-Beam Type Platforms; and Fixed and Portable Ladders


INITIAL STATEMENT OF REASONS


INFORMATIVE DIGEST OF PROPOSED ACTION/PLAIN ENGLISH OVERVIEW

 

Section 1637. General Requirements.

Subsection (n)

Existing subsection (n) provides general access requirements for scaffolds. Subsection (n)(2)(B) requires that prefabricated scaffold steps or stairs comply with ANSI A10.8-1977, Safety Requirements for Scaffolding. A proposed amendment adds the title of the standard and incorporates by reference the latest edition of this standard. The requirements for scaffold steps or stairs in the latest published edition have not changed since the 1977 edition of the publication. Therefore, the proposal will have no effect upon the regulated public other than to reference the latest published edition of the standard that is more readily available to the public than the 1977 edition.

Section 1660. Suspended Scaffolds for Loads of 425 Pounds or Less.

Subsection (f). Ladder-Type and Needle Beam-Type Platforms

Existing subsection (f) provides that ladder-type and needle beam-type platforms be constructed in accordance with ANSI A10.8-1977, Safety Requirements for Scaffolding. Proposed amendments will incorporate by reference the 1988 edition, the newest publication, of the

ANSI A10.8 standard for platforms placed in service after the effective date of the regulation.

The basic construction requirements for these types of platforms have not changed in the latest edition of the ANSI A10.8 standard. Referencing the latest edition of the standard will have no effect upon the regulated public other than to ensure platforms currently placed into use are constructed and used according to the most current accepted industry practices.

Subsection (g)

Existing subsection (g) requires the use of personal fall protection for employees working from suspended scaffolds within the scope of Section 1660 by the use of a safety belt and lanyard. As of January 1, 1998, Article 24 of the Construction Safety Orders prohibits the use of safety belts for use in fall arrest systems. Proposed amendments clarify that employees shall be provided fall protection meeting the requirements of Article 24 of the Construction Safety Orders. The proposal will have no effect upon the regulated public, since safety belts are already prohibited for use in fall arrest systems.

Section 3277. Fixed Ladders.

Subsection (a)

Depending on the installation date of fixed ladders, existing subsection (a) requires compliance with either ANSI A14.3-1956 or ANSI A14.3-1984. This ANSI standard was revised again in 1992. It would be confusing to add a third compliance date to subsection (a) in order to reference the latest published addition of this ANSI standard. Therefore, amendments are proposed to require that fixed ladders be approved as defined in Section 3206 of the General Industry Safety Orders. The term "approved" as defined in Section 3206 means in part that installations or materials meet the recommendations of a nationally recognized standard. Fixed ladders are manufactured and installed in accordance with ANSI national consensus standard requirements. The proposal will eliminate the need for three separate compliance dates in subsection (a) and have no effect upon the regulated public.

Section 3278. Portable Wood Ladders.

Existing Section 3278 provides that portable wood ladders meet the requirements of

ANSI A14.1-1981. Additionally, the regulation provides that ladders placed in service prior to the effective date of the regulation meet the provisions of the ANSI A14.1 standard in effect at the time such ladders where placed in service.

Board staff has determined that the reference to ANSI A14.1-1981 is incorrect and that the standard was actually effective as published in 1982. However, this will have no effect on the proposed revisions. The proposal will require ladders placed in service after the new effective date of the regulation (to be determined by the Office of Administrative Law) to meet the requirements of the 1994 edition of this standard which will be incorporated by reference.

Consistent with the regulation’s existing language, the proposal requires ladders placed in service on or before the new effective date of the regulation to meet the provisions of the ANSI A14.1 standard in effect at the time the ladder was placed in service. Ladders are designed to meet the requirements of the applicable ANSI standard in effect at the time of manufacture. Therefore, the proposed amendments will have no effect upon the regulated public other than the employer/user will have to ensure ladders recently placed into service meet current ANSI standard requirements.

Section 3279. Portable Metal Ladders.

Existing Section 3279 provides that portable metal ladders meet the requirements of ANSI A14.2-1982. Additionally, the regulation provides that ladders placed in service prior to the effective date of the regulation meet the provisions of the ANSI A14.2 standard in effect at the time such ladders where placed in service. 

The proposal will require ladders placed in service after the new effective date of the regulation (to be determined by the Office of Administrative Law) to meet the requirements of ANSI A14.2-1990, which will be incorporated by reference. Consistent with the regulation’s existing language, the proposal requires ladders placed in service on or before the new effective date of the regulation to meet the provisions of the ANSI A14.2 standard in effect at the time the ladder was placed in service. Ladders are designed to meet the requirements of the applicable ANSI standard in effect at the time of manufacture. Therefore, the proposed amendments will have no effect upon the regulated public other than to have the employer/user ensure ladders recently placed into service meet current ANSI standard requirements.

Section 3280. Portable Reinforced Plastic Ladders.

Existing Section 3280 provides that portable reinforced plastic ladders meet the requirements of ANSI A14.5-1982. Additionally, the regulation provides that ladders placed in service prior to the effective date of the regulation meet the provisions of the ANSI A14.5 standard in effect at the time such ladders were placed in service.

The proposal will require ladders placed in service after the new effective date of the regulation (to be determined by the Office of Administrative Law) to meet the requirements of ANSI A14.5-1992, which will be incorporated by reference. Consistent with the regulation’s existing language, the proposal requires ladders placed in service on or before the new effective date of the regulation (to be determined by the Office of Administrative Law) to meet the provisions of the ANSI A14.5 standard in effect at the time the ladder was placed in service. Ladders are designed to meet the requirements of the applicable ANSI standard in effect at the time of manufacture. Therefore, the proposed amendments will have no effect upon the regulated public other than to have the employer/user ensure ladders recently placed into service meet current ANSI standard requirements.

DOCUMENTS INCORPORATED BY REFERENCE

  1. The American National Standards Institute (ANSI) ANSI A10.8-1988, Scaffolding Safety Requirements.
  2. The American National Standards Institute (ANSI) ANSI A14.1-1994, for Ladders-Portable Wood-Safety Requirements.
  3. The American National Standards Institute (ANSI) ANSI A14.2-1990, for Ladders-Portable Metal-Safety Requirements.
  4. The American National Standards Institute (ANSI) ANSI A14.5-1992, for Ladders-Portable Reinforced Plastic-Safety Requirements.