Cadkiller
REGISTERED
Hi Group,
I have detailed a few ships ladders with a 4" tread and a 7" riser, to have the owner request that it be replaced. I have tried to explain to OSHA that this combination is very awkward/dangerous to walk down facing forward and also awkward to walk up as it requires you to take baby steps. The design team is drawing them this way because of the current codes, not knowing that they are awkward/dangerous IMO. I have attached an image of one of them which wasn't replaced and remains as is. I could only imagine how many other projects have been designed and built like this.
Osha's reply is as follows.
Please note that the requirements for ship stairs in 29 CFR 1910.25 are consistent with ANSI/ASSE A1264.1-2007, Safety Requirements for Workplace Walking/Working Surfaces and Their Access,’ Workplace, Floor, Wall, and Floor Openings,‘ Stairs and Guardrail
Systems. Additionally, § 1910.25(b)(8) requires employers to ensure that ship stairs “are used only when the employer can demonstrate that it is not feasible to provide standard stairs.”
Specific requirements for ship stairs are located at 29 CFR 1910.25(e). Paragraph (e)(2) requires that ship stairs have open risers with a vertical rise between tread surfaces of 6.5 to 12 inches (17 to 30 cm). OSHA believes that the tread depths provided in 1910.25(e) do not pose hazards when ship stairs are used, as the open risers on these stairs would give an additional space for the foot when needed.
Finally, to change these requirements, OSHA would need to conduct notice-and-comment rulemaking. OSHA does not currently plan to conduct rulemaking on 29 CFR 1910.25, but should the agency do so in the fixture, we will evaluate the dimension requirements for ship stair riser heights and tread depths as part of the rulemaking.
Let me know your thoughts regarding this.
Sincerely,
Ed B
I have detailed a few ships ladders with a 4" tread and a 7" riser, to have the owner request that it be replaced. I have tried to explain to OSHA that this combination is very awkward/dangerous to walk down facing forward and also awkward to walk up as it requires you to take baby steps. The design team is drawing them this way because of the current codes, not knowing that they are awkward/dangerous IMO. I have attached an image of one of them which wasn't replaced and remains as is. I could only imagine how many other projects have been designed and built like this.
Osha's reply is as follows.
Please note that the requirements for ship stairs in 29 CFR 1910.25 are consistent with ANSI/ASSE A1264.1-2007, Safety Requirements for Workplace Walking/Working Surfaces and Their Access,’ Workplace, Floor, Wall, and Floor Openings,‘ Stairs and Guardrail
Systems. Additionally, § 1910.25(b)(8) requires employers to ensure that ship stairs “are used only when the employer can demonstrate that it is not feasible to provide standard stairs.”
Specific requirements for ship stairs are located at 29 CFR 1910.25(e). Paragraph (e)(2) requires that ship stairs have open risers with a vertical rise between tread surfaces of 6.5 to 12 inches (17 to 30 cm). OSHA believes that the tread depths provided in 1910.25(e) do not pose hazards when ship stairs are used, as the open risers on these stairs would give an additional space for the foot when needed.
Finally, to change these requirements, OSHA would need to conduct notice-and-comment rulemaking. OSHA does not currently plan to conduct rulemaking on 29 CFR 1910.25, but should the agency do so in the fixture, we will evaluate the dimension requirements for ship stair riser heights and tread depths as part of the rulemaking.
Let me know your thoughts regarding this.
Sincerely,
Ed B
