The ladder rule in general industry is short. Under 29 CFR 1910.23(b)(9), the employer must ensure that "ladders are inspected before initial use in each work shift, and more frequently as necessary, to identify any visible defects that could cause employee injury." The next paragraph says what happens when the inspection finds one: the ladder is tagged "Dangerous: Do Not Use" and removed from service until it is repaired or replaced. This article covers which ladders the rule applies to, what counts as a defect, how the tag-out works, how the construction rule differs, and what a shift check should record.
A note on scope: this summarizes federal OSHA standards for general industry, found in Part 1910, with a short section on the construction standard in Part 1926. States with their own OSHA-approved plans can set different rules, and nothing here is legal advice.
Section 1910.23 applies to "all ladders," with two exceptions in paragraph (a): ladders used in emergency operations such as firefighting, rescue and tactical law enforcement, or in training for them, and ladders designed into or forming an integral part of machines or equipment. Everything else is in: portable stepladders and extension ladders, fixed ladders on tanks and buildings, mobile ladder stands and platforms, and stepstools. The inspection duty sits among the "general requirements for all ladders" in paragraph (b), so it applies to every one of those types.
Paragraph (b)(9) fixes the timing: before initial use in each work shift. A ladder used on three shifts is inspected three times a day. "And more frequently as necessary" adds a second trigger: a ladder that has been dropped, struck or exposed to something that could damage it is looked at again before the next climb.
The object is "any visible defects that could cause employee injury." It is a visual check, not a load test; it is done where the ladder is; and it looks for the defects that matter to safety, which the rest of the section helps define.
The text names no inspector qualification and requires no written record of the shift check. The record is a choice, and the end of this article explains why most sites make it anyway.
General industry's ladder standard does not list defects. Its condition requirements do the same job, because a ladder that no longer meets them is defective. Paragraph (b) requires that:
Paragraph (c) adds two conditions for portable ladders: rungs and steps of portable metal ladders are "corrugated, knurled, dimpled, coated with skid-resistant material, or otherwise treated to minimize the possibility of slipping," and each stepladder has "a metal spreader or locking device that securely holds the front and back sections in an open position while the ladder is in use."
The construction standard puts names to the structural defects. 1926.1053(b)(16) lists "broken or missing rungs, cleats, or steps, broken or split rails, corroded components, or other faulty or defective components." It is a fair description of what the general industry inspector is looking for, too.
Paragraph (b)(10) leaves no room for a ladder to stay in use while a repair is arranged: "Any ladder with structural or other defects is immediately tagged 'Dangerous: Do Not Use' or with similar language in accordance with § 1910.145 and removed from service until repaired in accordance with § 1910.22(d), or replaced." Two other standards are pulled in by that sentence.
The tag, 1910.145(f). OSHA's rule on accident prevention tags requires a signal word and a major message. Danger tags are reserved for "major hazard situations where an immediate hazard presents a threat of death or serious injury," which is why the ladder rule asks for "Dangerous"; the major message, such as "Do Not Use," names the instruction. The signal word must be readable from at least five feet, the tag is attached "as close as safely possible" to the hazard "by a positive means such as string, wire, or adhesive that prevents their loss or unintentional removal," and it stays on until the hazard is eliminated.
The repair, 1910.22(d). The walking-working surfaces rule requires hazardous conditions to be corrected or repaired before an employee uses the surface again, or guarded until they are, and when a repair "involves the structural integrity" of the surface, a qualified person performs or supervises it. A cracked rail or a bent rung is structural; a missing foot pad may not be, but the ladder still comes out of service.
The alternative is replacement, which for many portable ladders is the realistic outcome.
The person doing the shift check is usually the person about to climb, and paragraph (c) sets the conditions of use for portable ladders:
For climbing, paragraph (b) requires each employee to face the ladder, keep at least one hand on it, and carry nothing "that could cause the employee to lose balance and fall."
Fixed ladders and mobile ladder stands have their own design rules in paragraphs (d) and (e), and the standard's note points to 1910.28 for fall protection on fixed ladders.
Construction sites follow 1926.1053. Its inspection rule, paragraph (b)(15), reads: ladders "shall be inspected by a competent person for visible defects on a periodic basis and after any occurrence that could affect their safe use." It names an inspector and does not tie the check to each shift. The remedy is similar: a defective portable ladder is marked as defective or tagged "Do Not Use" and withdrawn until repaired, and a defective fixed ladder may instead be blocked, for example with a plywood panel across several rungs. A contractor's crew in a plant brings its own standard with it; the plant's employees are under 1910.23.
Our ladder inspection checklist, free as a PDF, Excel or Word file, follows paragraphs (b)(9) and (b)(10) and the condition rules above.
Ladder:
Condition:
Result:
Fixed ladders and mobile ladder stands need their own versions, with the clearance, rail extension, caster and handrail items from paragraphs (d) and (e).
The standard requires no record, but the tag-out in (b)(10) starts a repair or a replacement that someone has to own, the ladder that keeps failing is the one to retire, and a check done by the person at risk minutes before the risk is worth thirty seconds of evidence.
The same approach applies to the other daily and weekly safety checks, from walking-working surfaces to fire extinguishers; see safety inspections that get done.
If your sites run shift ladder checks alongside their other safety rounds, see how Vardian handles safety inspections and corrective action: a scan on each ladder, the condition items captured where it stands, and a failed check that becomes a tag-out and a work order.
Bring a round, an inspection or a maintenance process to a demo, and we'll show how it runs in Vardian.
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