LADDERS AND PLATFORMS

SAFETY RULE #2

“All work is performed from platforms,

and ladders are not used for frequent
access. All elevated areas and platforms
have standard stairs and railings.”

Implementation Guidance

1 15-Jan-2019
2 – LADDERS AND PLATFORMS

All work is performed from platforms, and ladders are

not used for frequent access. All elevated areas and
platforms have standard stairs and railings

• Ladders are used for access only, and their use is

controlled and authorized by permit
Management
• Temporary elevated work is provided with a secure
platform with appropriate fall protection
• Elevated platforms are provided with standard safe
access, steps, handrails and edge protection

• I always provide appropriate temporary work

Supervisors platforms when needed
• I always take action when I see someone working
from a ladder

Employees • I always work from a platform and not from a ladder

2 15-Jan-2019
CONTENTS
2 – LADDERS AND PLATFORMS ............................................................................................................... 2
CONTENTS ............................................................................................................................................... 3
BACKGROUND ......................................................................................................................................... 4
DEFINITIONS............................................................................................................................................ 5
MANAGEMENT REQUIREMENTS ............................................................................................................ 7
2.1 Ladders are used for access only, and their use is controlled and authorised by permit ......... 7
2.2 Temporary elevated work is provided with a secure platform with appropriate fall protection
................................................................................................................................................... 9
2.3 Elevated platforms are provided with standard safe access, steps, handrails and edge
protection ................................................................................................................................ 15
SUPERVISORS REQUIREMENTS ............................................................................................................. 28
2.4 I always provide appropriate temporary work platforms when needed ................................ 28
2.5 I always take action when I see someone working from a ladder ........................................... 29
EMPLOYEES REQUIREMENT .................................................................................................................. 30
2.6 I always work from a platform and not from a ladder ............................................................ 30

3 15-Jan-2019
BACKGROUND
RULE All work is performed from platforms, and ladders are
not used for frequent access. All elevated areas and
platforms have standard stairs and railings.
INTENT Employees shall be protected from the risk of falls from all work areas that
are not situated at ground level. To provide secure platforms to work from
with appropriate fall protection and suitable access, to reduce the risk of
injuries from falls.
HISTORY
Incidents have occurred internally resulting in significant injuries or fatality. History shows
that portable ladders and fixed ladders that are used frequently cause multiple numbers of
severe injuries.

Fatal accident –July 2013 Broken Elbow and Knee –Jan 2016

4 15-Jan-2019
DEFINITIONS
The meaning of ladders in this guidance includes leaning ladders, stepladders and fixed
ladders. Step-stools consisting of two steps should be considered under the definitions for
platforms on the next page.
Leaning Ladder Examples

Step Ladder Examples

Fixed Ladder Examples

5 15-Jan-2019
Platforms are categorised in this guidance in two different ways:
1. FIXED or MOBILE.
2. For WORK or for ACCESS.
FIXED platforms are any horizontal surface above floor level designed for standing on, that is
attached to the building structure or otherwise immovable.
MOBILE platforms also have a horizontal surface designed for standing on, but can be
moved from one location to another.
WORK platforms should be considered any platform where a person can work, whether for
routine tasks or less frequent tasks, including maintenance and sanitation. Any task that
requires the use of both hands should be considered work.
ACCESS platforms are only used briefly for access or inspection purposes where work is
never performed. For example, a low-level step used with a continuous hand-hold to look
into a vessel, or a landing used to transition from a stair to a platform.
FIXED WORK platform example FIXED ACCESS platform example

MOBILE WORK platform example MOBILE ACCESS platform example

6 15-Jan-2019
MANAGEMENT REQUIREMENTS
2.1 Ladders are used for access only, and their use is
controlled and authorised by permit
Safety Rules Audit
An external auditor will check:
• Fixed ladders with infrequent use are locked.
• Portable ladders are locked.
• A permit process is in place to restrict and control the appropriate use of ladders.
• Ladders that are not locked (for example, because of frequent use) have been risk
assessed and prioritised plans exist for eliminating or controlling the risks.
Scoring Guide (3.2.1)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Either a permit system for authorised use is in place OR all portable
ladders and infrequently used fixed ladders over 3m (10’), are locked.
8 - Substantially implemented. All infrequently used fixed ladders over 3m (10’) are locked. All
portable ladders are locked. A permit system for authorised use is in place and effective.
10 - Yes - Substantially implemented and effective. All portable ladders and infrequently used fixed
ladders are locked and controlled. All other ladders risk assessed with effective plans.
Expectation
Sites will apply physical access controls to, or lock up, fixed and portable ladders to prevent
unauthorised use. Fixed ladders include those to access the roof, tops of tanks or other long
fixed ladders with infrequent use. Use of these will require a permit, which can be issued
only after it is confirmed that they will be used for access only. For portable ladders, a
decision tree like the one shown in requirement 3 should form part of the ladder permit
process, to ensure that alternatives have been considered, and that a ladder is appropriate
for the task.
For fixed ladders that are regularly used for access to production equipment they do not
need to be locked, but where possible they should be changed for steps, especially if they
are long (more than 3m or 10’). To consider when a fixed stepladder or fixed ladder for
access may be acceptable, a case by case risk assessment should be completed, but
generally it would need to meet all of the following requirements:
• The structure or layout does not make stairs or other basic means practical.
• Short vertical distance (less than 3m or 10’) AND/OR the means of access is used
infrequently (less than once per month).
• The user will not be carrying any large tools or any other equipment when using the
means of access.
• Only one user will be foreseen to use the means of access at the same time.
When designing and installing new equipment, the use of fixed ladders should always be
avoided for any regular or frequent access required for production, sanitation or
maintenance.

7 15-Jan-2019
Examples

Fixed ladders with infrequent use

should be locked to prevent
unauthorised use.
This is particularly important
where the use of a fixed ladder
may also trigger work at height
requirements.

Portable ladders should be locked to This was found on a site, to access the
prevent unauthorised use. roof and freely available for anyone to
use. The condition is poor.

8 15-Jan-2019
2.2 Temporary elevated work is provided with a
secure platform with appropriate fall protection
Safety Rules Audit
An external auditor will look for:
• A plan is in place to reduce the number of portable ladders on site.
• Evidence that the decision tree process is being used.
• Evidence that the use of ladders is restricted and controlled.
• Visual confirmation that other means of access is available and used.
• Assessments for the regular use of podium steps and aircraft steps.
Scoring Guide (3.2.3)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Ladders are locked and controlled by permit. Alternatives are available
and utilised in some situations.
8 - Substantially implemented. Portable ladders are not available for work and alternatives are
routinely available and utilised by employees. All mobile platform use is assessed.
10 - Yes - Substantially implemented and effective. Portable ladders are not used on site by
contractors or employees and alternative methods are available and utilised.
Expectation
The site should encourage using alternative equipment to ladders. A plan to eliminate or
reduce the use of ladders should be developed. The decision tree process below, or similar,
should be used to identify appropriate equipment to work from. It should be noted that the
term ‘fall protection’ does not specifically refer to the use of harnesses and fall-arrest
equipment. As explained in the Work at Height Safety Rules (3), individual protection such
as harnesses is the least preferred means of fall protection. If work at height cannot be
avoided, then the most preferred fall protection is fixed platforms with stairs and standard
railings. Examples on the following pages explain some of the alternative equipment when
fixed access is not practical. Some forms of Mobile Elevating Work Platforms may require
the additional use of a harness and fall-arrest equipment.
Appropriate alternative equipment should be available on site or specified for contract
work. Any ladders should be locked up to prevent unauthorised use and be part of the
permit system. This is a general site expectation that applies to company employees and all
contractors and visitors, and includes routine work, and non-routine work such as contracts
and projects.
It is important to note that the ladder permit system is different from the work at height
permit process. It is required any time a ladder is used, regardless of height, while most
countries have minimum heights before specific ‘work at height’ regulations apply. The
purpose of this requirement, to provide platforms for elevated work, is to avoid work from
ladders altogether. As such, a ladder is not the appropriate equipment to perform work at
height.

9 15-Jan-2019
Ladder Selection Decision Tree

10 15-Jan-2019
The work at height permit process referred to in safety rule 3 is a more detailed process that
considers a complete work task, including the work area, access to the area, and the
transport of tools and equipment, especially for irregular work. A work at height permit to
work process could determine that a ladder is appropriate for access to a temporary work
area, in which case the ladder permit would also be required.
For regular and routine elevated work that cannot be performed from fixed platforms, it
should first be assessed with the work at height, or similar process, to determine the
appropriate equipment. If this is a non-adjustable stable MOBILE platform, such as podium
steps or aircraft steps that are not powered and do not need the additional use of a fall-
arrest system, then the combination of equipment and task can be approved so that the
permit process would not need to be repeated each use. Additional controls must be
implemented to ensure that the right equipment is always available, that it is only used for
the approved task, and employees use the equipment appropriately with effective training
and supervision.
Examples
Mobile Elevating Work Platforms (MEWPs)

11 15-Jan-2019
Portable Scaffolding. The top work platform should always include a standard rail for fall
protection whenever possible. Without a standard railing, alternative fall protection
controls are required.

Podium steps are good alternatives to leaning Ladders and portable Stepladders. They have
a defined platform for working on with a safety rail all the way round to protect the worker.

12 15-Jan-2019
Aircraft steps. Used when access is required right up to the side of an item

Desk Glider. Very useful to replace ladders used in offices

www.workingatheightltd.com/deskglider

13 15-Jan-2019
Temporary access to a scaffolding platform using a ladder is acceptable providing:
• the ladder is secured at the top
• there is a gate in the scaffold to prevent falls when the ladder is not being accessed
• Tools and equipment are not carried up the ladder

Manual hoist with internal braking system are useful for low frequency lifts of tools and
equipment for example lifting filters and tools to the top of powder silos.

14 15-Jan-2019
2.3 Elevated platforms are provided with standard
safe access, steps, handrails and edge protection
Safety Rules Audit
An external auditor will look for:
• Evidence that the site has assessed work platforms and the means of access.
• All stairs at an angle in the ‘Accident-Prone Range’ have instructions to descend facing
the steps.
• Plans are in place to remove or improve any non-standard access to work platforms.
• Evidence that new platforms, steps, stairs and guardrails meet the required standards
(agreement in design contracts, standards referenced in quotations etc.)
• Interview engineering staff about their awareness of relevant design standards.
• If the site has identified locations where operators work at the top of access stairs /
steps and there is a risk of falling.
• A sample of platforms over 460 mm (18 inches) with safety barrier rails and steps.
• A sample of WORK platforms under 460 mm (18 inches) with appropriate rails, visible
edges and steps.
• A sample of ACCESS platforms under 460 mm (18 inches) with handholds.
• Evidence that platform loading points have been assessed.
• Visual checks during a site visit
Scoring Guide (3.2.2)
1 - No - Nothing has been done.
3 - New installations are reviewed against standards but they are not incorporated into the design
stages. Local fabricators manufacture based on experience.
5 - Partially implemented. All platforms reviewed. 50% standard safe access, steps, handrails and
edge protection.
8 - Substantially implemented. All platforms reviewed. 80% standard safe access, steps, handrails
and edge protection. All platforms evaluated with no residual Significant Risk.
10 - Yes - Substantially implemented and effective. All platforms evaluated, 100% standard safe
access, steps, handrails and edge protection. Specifications for new installations
Expectation
Access to Platforms
Where employees are required to routinely and regularly work (several hours per shift at a
recognised work station) on a work platform, access to this location should be through a set
of steps and suitable handrail. Any fixed vertical ladders that lead to an operator’s regular
work station should be reviewed. New installations for steps, stairs and handrails should
conform to the requirements in ISO 14122 Permanent means of access to machinery.
Where current stairs are in the accident-prone range (> 42°) instructions will be clear to
ascend and descend facing the stairs. New installations should avoid this range.
Where sites need to improve access to work platforms, steps, stairs and guard rails, suitable
design standards will be referenced and recorded. Two useful and common international
standards include the following, available to view on the Global ORM Teamsite.
• ISO 14122 parts 1 to 4 – Safety of Machinery, Permanent means of access to
machinery.
• EEMUA 105 (Engineering Equipment and Materials Users Association) Factory
Stairways, Ladders and Handrails
15 15-Jan-2019
The standard Risk Assessment tool for Ladders and Platforms should be used for the review.
Examples

New Installations should not be designed

with pitch in the ‘Accident Prone Range’

16 15-Jan-2019
Safety Gates
Where operators and maintenance personnel are required to work within 860mm (34”)
from the top of steps, stairs or fixed vertical ladders, a safety gate is required to prevent
falling. The area to be considered is measured as a rectangle that extends the width of the
opening and is 860mm (34”) deep from the edge of the opening, as shown in the diagram
below. If a safety gate is not installed, then work should be prohibited within this area. The
area may also be referred to as the ‘landing’ area.

Platform

Edge Protection

860mm
(34”)

Stair or ladder opening onto platform

A stairway or fixed ladder landing area that is used for egress only where no work is
performed would not require a safety gate, unless it was required by local regulations or
considered an appropriate control from a risk assessment. For example, an off-set stair with
a landing that is not part of the work platform, as follows:

Platform

Edge Protection

860mm
Landing
(34”)

Stair opening onto landing

Safety gates are an effective way to prevent falls from fixed ladders and steps, especially
from stepping inadvertently into the opening while performing work. They should be
designed to open easily and close automatically, e.g., by the use of springs or the effects of
gravity. They should swing open only onto a landing and should close gently and securely.
Chains and lift up single bars should not be used as a substitute for a safety gate.
Where safety gates are not required by regulation, the standard Risk Assessment tool for
Ladders and Platforms should be used to assess their suitability and prioritise
improvements.

17 15-Jan-2019
Examples

This work platform requires a safety Safety gate installed at the top of a
gate as the work area is less than vertical ladder because the work area less
860 mm from the top of the steps. than 860 mm from top of steps.
Operator spends 10 minutes each hour on
activities

Safety Gate for “work area” at top of steps… and vertical ladder.

18 15-Jan-2019
19 15-Jan-2019
Edge Protection
The site will review fall risks from platforms as follows:
• Three steps or more: Any platform or exposed edge with a height greater than 460
mm (18 inches) will have a safety barrier rail to prevent falls as per ISO 14122 part 3.
(photo 2.1).
This height has been chosen because it is the maximum recommended with two
standard steps. Any platform over this height requires three or more steps.
• Two Steps: A low level WORK platform between 230 mm (9 inches) and 460 mm (18
inches) high, such that it requires an intermediate step, shall have the step extend
the entire length of the edge, or use rails to guide walking traffic to the step.
If the width of the platform, to the front and back of the worker, is less than 860 mm
(34 inches) then it shall have a rail to prevent the operator unexpectedly stepping
backwards off the platform.
• One Step: For a low level WORK platform less than 230 mm (9 inches) high, if the
width of the platform, to the front and back of the worker, is less than 610 mm (24
inches) then it shall have a rail to prevent the operator unexpectedly stepping
backwards off the platform. (photo 2.2).
• No WORK platform shall have a dimension less than 610 mm (24 inches).
• Where rails are not required, the edge should be highlighted (photo 2.4).
• Any low level ACCESS platform less than 460 mm (18 inches) high, shall have a fixed
handhold for the operator to use while stepping on and off. (photo 2.5, 2.6).
• Where steps are used to access a platform, step heights should be equally spaced
with an angle between 30° and 42°, with dimensions consistent with ISO 14122 part
3, or OSHA 1910.24 – Fixed Industrial Stairs:

Example from Example from

OSHA 1910.24 ISO 14122 part 3
Angle Rise (in.) Run (in.) h (mm) g (mm)
30° 6.5 11 160-177 278-306
33° 7 10.5 170-186 262-287
36° 7.5 10 178-195 245-269
40° 8 9.5 189-206 225-246
41° 8.25 9.25 191-208 220-240
(600 < g+2h < 660)

20 15-Jan-2019
Examples
Photo 2.1

Platform > 460 mm (18 inches)

Safety barrier rails

Safety gate
(work area less than
860 mm (34 inches)
from top of steps)

Steps Angle 30 - 42o

and equally spaced
Photo 2.2a Photo 2.2b

Work platform for operators to inspect Minimum width for a low level work
bottles. platform is 610 mm (24 inches).
Potential to step back and fall.

21 15-Jan-2019
Photo 2.3a Photo 2.3b

Platform meets minimum width of 610 mm

(24 inches). Ensure the placement has the
normal work position centred, not towards
a back edge.
Photo 2.4a

Edge marking
The work platform is greater than
860 mm (34 inches) wide
Height is < 460 mm (18 inches)

Photo 2.4b

The contrasting green colour acts as

Edge marking
The work platform is greater than
860 mm (34 inches) wide
Height is < 460 mm (18 inches)

22 15-Jan-2019
 Photo 2.5a Photo 2.5b

Handle
Handhold

ACCESS
Step

ACCESS platforms less than 460 mm (18 inches)

Small fixed steps with handhold for brief inspection
If handles are used, signage to inform the operator should be in place.
It is possible to use handles or handholds with small single step
platforms, providing the platform is used as ACCESS only, for short
duration, is stable and fixed to prevent movement.

Photo 2.6a Photo 2.6b

Fixed and secure against movement

Could be used for ACCESS with a handhold.
Not to be used as a WORK platform.

Not fixed – no handhold

23 15-Jan-2019
Photo 2.7a Photo 2.7b

ACCESS platforms greater than than 460 mm (18 inches).

Rails are required to assist the operator in climbing up and down the ACCESS platform.
These ACCESS platforms should be stable and fixed to prevent accidental movement
including over balancing.

Photo 2.8a Photo 2.8b

New or modified platforms, handrails and steps should be designed to ISO 14122 parts 1 to
4, and included in the specification when placing orders. Contact Regional ORM for details.

24 15-Jan-2019
Materials Handling
Any platform where ingredients, materials or goods are delivered will have a constant
engineered solution to prevent operators from falling. This usually means the installation of
an ‘Up and Over” safety gate, where the edge is constantly protected (not optional) but still
allows for the movement of materials.
Examples
Drum loading before and after. Drums are lifted to the platform so Operators can pump the
product out with portable pumps on the platform.

Edge left unprotected. Up and over gates installed

25 15-Jan-2019
The following two examples show gates that appear to offer protection from falling but do
not.

The outer gate does not lock in the

closed position, when the inner gate is
open.

Outer gate.

Inner gate.

This means that it appears that there is

a gate in place but anyone can push
against it and it will open away from the
platform

Inner gate open

Outer gate APPEARS to offer protection

but can easily be pushed open.

The gates open outwards no protection

is offered

The securing bolt is a manual operation

and is missing.

26 15-Jan-2019
Safety Gates can be manufactured to suit most applications with restricted space and
height.

27 15-Jan-2019
SUPERVISORS REQUIREMENTS
2.4 I always provide appropriate temporary work
platforms when needed
Safety Rules Audit
An external auditor will:
• Check documented procedures.
• Check documentation of training and communications.
• Look for physical evidence of pre-approved equipment.
• Interview supervisors through a conversation to understand temporary access needs
in the area and current methods of access.
• Observe behaviour.
Scoring Guide (3.2.4)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all the verification steps align, and substantial improvement is
required.
8 - Substantially implemented. Evidence from all the verification steps is aligned, and only minor
improvements are recommended.
10 - Yes - Substantially implemented and effective. Evidence from all the verification steps is aligned
and consistently maintained. No further improvements identified.
Expectation
When fixed access to equipment at height is not available, the use of temporary work
platforms, as described in previous examples, may be appropriate. For routine access, like
unblocking overhead conveyors, operating valves or inspecting hoppers, the appropriate
equipment can be assessed and pre-approved for specific tasks.
It is the supervisor’s responsibility to ensure that the pre-approved equipment is available
when needed, and that employees under their control do not work from ladders.
For non-routine tasks without pre-approved equipment, an assessment is required to
identify the appropriate equipment, most likely as part of a work-at-height permit process.
The supervisor of any such work is responsible for ensuring that the appropriate equipment
is available when needed. This includes maintenance and project engineering work, as no
person on site can work from a ladder, including contractors. A ladder can only be used
where it is explicitly identified by an assessment process as appropriate and has an
approved permit.

28 15-Jan-2019
2.5 I always take action when I see someone working
from a ladder
Safety Rules Audit
An external auditor will:
• Check documentation of training and communications.
• Review use of the OSCAR board, and follow-up actions.
• Look for physical evidence that ladder use is controlled.
• Interview supervisors through a conversation to understand their current level of
awareness, and involvement regarding ladder usage.
• Observe behaviour.
Scoring Guide (3.2.5)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all the verification steps align, and substantial improvement is
required.
8 - Substantially implemented. Evidence from all the verification steps is aligned, and only minor
improvements are recommended.
10 - Yes - Substantially implemented and effective. Evidence from all the verification steps is aligned
and consistently maintained. No further improvements identified.
Expectation
Once the use of ladders is restricted and controlled on site, and alternative temporary work
platforms are available, then it is expected that all supervisors will confront any person
observed working from a ladder. This would include the employees they are responsible for
and any other person in their area, such as maintenance, sanitation and contractors. In
addition to their own area of responsibility, it should also apply to any location on site, if the
opportunity arises.
Confrontation could include a request to pause work, a request to view the permit, and
assistance with obtaining the appropriate equipment, or referral to the person able to
resolve the issue. On a production line, such a confrontation would require a red Safety
Check on the OSCAR board with notes of the follow-up action taken.

29 15-Jan-2019
EMPLOYEES REQUIREMENT
2.6 I always work from a platform and not from a
ladder
Safety Rules Audit
An external auditor will:
• Check documented procedures.
• Check documentation of training and communications.
• Review use of the OSCAR board, and follow-up actions.
• Look for physical evidence that ladder use is controlled, that fixed platforms are
present, and that pre-approved equipment is available for temporary use.
• Interview employees through a conversation to understand their current level of
awareness, and use of platforms and ladders.
• Observe behaviour.
Scoring Guide (3.2.6)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all the verification steps align, and substantial improvement is
required.
8 - Substantially implemented. Evidence from all the verification steps is aligned, and only minor
improvements are recommended.
10 - Yes - Substantially implemented and effective. Evidence from all the verification steps is aligned
and consistently maintained. No further improvements identified.
Expectation
Employees should know the basic requirement that they do not work from a ladder. Once
ladder use is restricted and controlled, and the appropriate alternative equipment is
available, such as fixed platforms or temporary work platforms, then It should be made clear
to employees that they are expected to stop work and seek assistance if they believe it is
unsafe to proceed.
A ladder should only be used if it can be demonstrated using an assessment and approval
process that it is appropriate equipment for the specific task. Any ladder use in a production
area should be noted on the relevant OSCAR board.

30 15-Jan-2019