By Bruce Bolduc
Special to the Barrie Construction Association Report
There has been a lot of debate about the use of ladders in construction. In some areas, Ministry of Labour inspectors were issuing charges against workers and employers while in other regions, no one was being charged.
Employers and constructors have long looked for clarification of what constituted safe use of a ladder and where could they be used.
At one point in time, ladder use was allowed for work that was “short duration in nature.” This still led to a great deal of confusion. Falls from ladders continue to be arguably the largest single cause of injuries in Ontario. Most of these are from improper use of the ladder.
To that end, the Ministry published its position on ladder use in construction on January 3, 2012.
Note there has been no change in legislation about ladder use, specifically OHSA 213/91 sect. 26, the legislation that applies to working at heights, including ladders. Other relevant labour code sections are 78-84, 240 and 286.
The first point to be noted is that the Ministry has placed the decision to use a ladder squarely on the shoulders of the employer. This means that the first point in any investigation will be directed towards the employer in the event of an incident or accident.
When choosing to use a ladder for any task, the following points must be considered:
- Is a ladder the safest piece of equipment to use in this case?
- This decision cannot be based on ease or speed of production.
- A ladder used for access and egress is fine; however it must be secured at top and bottom.
- For any work over three metres., fall protection must be used.
- Is the ladder CSA approved and rated for the task?
- Can the worker attain three-point contact when required ? (Three-point contact must be continuous while ascending or descending the ladder.)
- Are the workers properly trained in the use of ladders?
- Does the “Site-specific health and safety program” address the hazards of using a ladder?
- Will the work being done adversely affect the stability of the ladder in any way?
- Has a site-specific hazard assessment been completed and submitted to the supervisor?
- Where possible, it is recommended that a manufacturers ladder stabilizers be used.
- A ladder with a built in work platform, built in accordance with CSA Standard CAN3-Z11 is preferred over a standard extension ladder.
- Grade 1 ladders are the preferred ladders to be used on a construction site, and only in accordance with the manufacturer’s specs.
- To be clear, where an employer intends to allow the use of a ladder for any work, the preferred method is to use a scaffold as per section 125(1). Ladders can be used when the assessment determines there is no risk, or all hazards identified have been mitigated. The employer shall ensure that the ladder and its use comply with the regulations and that all precautions for the protection of the worker have been taken.
To conclude the Ministry of Labour will be looking for a risk assessment before using the ladder. This assessment must be site specific and will be required to be produced at the inspector’s request.
For further information on construction industry ladder use, go to the Ministry of Labour’s web site at www.labour.gov.on.ca. You can also learn more at www.IHSA.ca or our web site, www.buildwithsafety.com.
Bruce Bolduc is a consultant and owner of Construction Workplace Safety Training Ltd.