Letters
Ladder-safety expert wants improvements.” LePeyre ladders offer
to correct, add info
(Editor’s Note: J. Nigel Ellis served as a source
for the article, “A safe climb,” which appeared
on p. 40 in the March issue of Safety+Health.)
CONCERNING THE LADDER ARTICLE in
the March issue, I would like to make
a few corrections and add what I hope
are presented as safety tips for users to
consider.
The photograph of the ladder on p. 43
reveals that the ladder is set up back to
front, which slopes the ladder rungs in a
forward direction, making a slip forward
and between the rungs a possibility with
an undesired result of falling through the
ladder or backward. Also, the portable
ladder is much too long for its applica-
tion for a height approximately half the
length of the ladder.
On p. 40, the use of a stand-off is
applauded to reduce gutter damage
and rain water overflow.
In Step 10, the major correction
is that all ladders must be held by
rounded horizontal rungs. Side rails of
vertical ladders should never be held
because while they provide a continu-
ous handhold (static), the hand will slide
if a fall occurs (dynamic). Refer to the
Ph.D. thesis of Justin Young, University
of Michigan 2011, at www.fallsafety.com
under “ladder improvements.” The
exception: a sloped ship’s ladder such
as the LaPeyre Ladder.
All grab bars should be horizontal
(exception: vertical grab bars up to 6
inches in length). Examples of practices
with horizontal grab bars are found
at www.fallsafety.com under “ladder
Write to us
10 Safety+Health | May 2012
sh.05.12.letters.indd 10
who may fall backward with the foot
grab bar rails, which must be grabbed
and provide an adequate handhold.
Step 16, “Access to Upper Land-
ing,” talks about the ladder extend-
ing 3 feet above the landing. What
is intended here is for the ladder to
be extended 3 feet, which includes
extension accessories. This complies
with an OSHA interpretation dated
Dec. 22, 2005, permitting the exten-
sion principle with an accessory in
lieu of the ladder itself. This has the
advantage of allowing walk-through
without disturbing the ladder hand-
hold and eliminating stepping around
the ladder required if the ladder rungs
themselves are raised, blocking walk-
through. Explaining why the trades
frequently do not extend the ladder
itself more than a few inches to reach
roofs is due to the great shift in center
of gravity needed to move from the
ladder to the roof, and which is best
achieved by walk-through instead of
climbing through the rungs with little
or no handholds.
Step 11: Three-point control is the
engineering term that matches feet and
hands to the climbing object (in this
case a ladder). Keeping the hands free
for climbing is a great principle, but it is
not intuitive and must be trained regu-
larly. The possibility of holding side
rails effectively, including fixed ladder
side rails, has been disproved by Justin
Young’s thesis. Only rungs should be
held on a ladder for effective grip in a
dynamic fall.
Note: The uppermost rung of a lad-
der should be the same height as the
step-off point. This will minimize the
exposure to the second rung having
less than 7 inches of space behind
the rung for the workboot to extend
into. The climber must also avoid the
foot-trap where it is placed in a space
where it jams as the foot moves or piv-
ots, tripping the climber and causing
catastrophic damage to the climber,
still trapped.
I would also like to address what hap-
pens when you must carry up tools,
notepads or instruments and yet climb
with nothing in the hands or under the
arms. The answer is a backpack, or pull
up on a cord, or, for heavy toolboxes,
lift by crane or hoist. A system used
by one company employs an overhead
pulley with a continuous rope to reach
the ground and small loops for attach-
ing materials when pulled from above.
One caution is to not risk the worker’s
center of gravity passing over a rail-
ing, as material loads get heavier either
for lifting or lowering on a large loop
through a pulley. Sometimes catching
a falling load on a rope has pulled a
worker over the railing, with disastrous
consequences, or caught fingers in the
pulley.
Some construction companies recog-
nize the danger of portable ladder use
without constant supervision and have
moved to scissor lifts and aerial buck-
ets, which themselves need repeated
training but at least provide a steady
work surface that a ladder rung cannot.
Extension side rails are the best bet
for reducing falls from ladders at transi-
tion points.
J. Nigel Ellis, Ph.D.
Ellis Fall Safety Solutions LLC
WILMINGTON, DE
Earplug expert takes issue
with statements
IN CHRIS BROWN’S article, “Compar-
ing temporary and permanent hearing
protectors” (February 2012, p. 56), he
uses the term “permanent” to describe
custom-molded earplugs and “tem-
porary” to describe other devices.
Because all earplugs, including custom
devices, must be replaced at some
point, once they are dirty, worn out
or lost, this distinction seems lacking.
Perhaps a more meaningful distinction
sh.nsc.org
4/11/12 2:06 PM
 Letters
Letter spotlight
Safety pros ‘must continue
to search for new methods’
This feedback is a response to a quote from “What’s Your
Opinion: Are all injuries preventable?” (May 2012, p. 74).
The following is one of the first responses: “They are
caused by an unsafe condition or act. Eliminate the condi-
tion or act, and the injury shouldn’t occur.” This is poten-
tially possible if all industries were all run by computers
and robots – and even then there is a possibility of a sys-
tematic mishap.
If managing a safety and health program was a matter of
“man-failures,” our jobs as safety professionals would be
to baby-sit adults. This outdated safety management style
was inspired by Herbert William Heinrich from the 1930s.
A more updated safety management style has been devel-
oped by Fred Manuele.
Unfortunately, many safety professionals continue to
use Heinrich’s analysis of the causation of mishaps. In
summary, Heinrich did pave the way for safety profes-
sionals to understand the causes of mishaps; however, we
as safety professionals must continue to search for new
methods and theories to continually improve and make
the workplace safer.
While the traditionalist will seek unsafe acts or conditions,
the systems person will look at what went wrong with the
system, perceiving something went wrong with the system’s
operation or organization that allowed the mishap to take
place. I cannot take credit for the idea of the previous sen-
tence. I have found it to be one of the most useful ways to
understand the anatomy of a mishap.
I encourage our employees to use the side rails of ladders.
Many times on construction sites the rungs accumulate mud
from shoes and boots. I attempt to have the rungs kept clean
at all times, but you know how that goes.
Stephen B. Williams, CSHM
Safety Director
Bell Electrical Contractors Inc.
St. Louis, MO
I was reading the Editor’s Note and wanted to respond.
Although OSHA and NIOSH don’t address the issue of using
side rails, it is not an accepted practice to use side rails.
• It is ergonomically safer to grip the ladder rungs.
• Ladder rails are wider so the individual cannot wrap their
hand around it.
• Holding the rails puts undue stress on your wrist.
• You have a firmer grip and greater strength holding the
rungs.
• In the event of a slip, you could lose your grip easier and
fall if holding the side rails.
David Arwood
EHS Specialist
Chemira Chemicals Inc.
Marietta (GA) Plant, North America
Use of the side rails would be more advisable, although
there is not a standard anywhere applying to this.
Use of side rails keeps your arms, hands and wrists closest to
a good ergonomic position, thus putting less stress on wrists.

Max Lafferty, GSP Steve Matlock

Occupational Safety & Health Specialist Safety Director
U.S. Air Force Murphy Bros. Trucking & Construction LLC
Whiteman AFB, MO Arcadia, LA

Rungs vs. rails: Readers weigh in on ladder safety
The Editor’s Note in the May issue of Safety+Health asked readers
to share their opinions on holding the side rails of a ladder versus
holding the rungs. Below are some of the responses; S+H will share
more next month.
The simple reason for grasping the rungs is one of control.
Unless one has the hands of André the Giant, you cannot
properly surround or grasp the side rails; you therefore do
not have proper control. The rungs, however, can be grasped
and properly held.
Steven Hess, CSP
It is our position that you climb by holding onto the rungs.
We don’t believe that a person is strong enough to hold them-
selves to the side rails if the foot slips off. The foot slips and
the person goes sliding down the ladder. Plus – we feel that if
a person is holding onto the rails they are more likely to strike
their face against the rungs if their foot slips and they fall for-
ward without having the arms in front of their face.
Pat Cochran
Safety Director
Wm. Blanchard Co.
Springfield, NJ

10 Safety+Health | July 2012 sh.nsc.org

sh.07.12.letters.indd 10 6/11/12 3:30 PM


Regarding Tip 10 and the use of the side rails in comparison
to the ladder’s rungs, I prefer the use of the ladder’s rungs
for these two reasons:
1. If the feet slip off of the rungs, you will have a “stronger”
and “longer” lasting grip to recover from the fall.
2. Using the rungs to assist in decent creates a mental
“cadence” or timing so to speak, joining the hands and
feet together rhythmically for the three points of contact.
Rodger Shelton
Director of Transportation and Maintenance
TARC
Houma, LA
With a career of over 25 years as an electrical contractor,
I’ve never seen a printed ruling either way in the argument
between using the rungs or the side rails on a ladder. As a
practicable matter, however, I would guess that most “expe-
rienced” users prefer using the rungs as the possibility of a
slip of the shoe/boot will give you a better chance at catching
yourself hanging onto the rung, as opposed to the side rail.
The rung gives you a horizontal handhold to clasp, whereas
the side rail only gives you a vertical surface to grab and hold
onto for dear life.
I would choose the rung whenever possible.
Gary Garber
Foreman
Town of Syracuse Public Works, Wastewater Treatment Plant
Syracuse, IN
I’ve been following your ladder safety article and appre-
ciate your continued insight into the matter. To answer your
question, I prefer and train workers to hold onto the rungs, but
allow them to hold onto the side rails if they feel more secure.  ever, would not be as hazardous with clumps of mud, snow
At the end of the day, my policy is three points of contact.
    
Matt Laverne
Risk & Safety Director
Douglas County Board of Commissioners
Office of Risk & Safety
Douglasville, GA  our techs were safest using the side rails.
First, if the employees are practicing a three-point contact
– be plenty satisfied.
Second, many stationary ladders utilize rounded rungs that
would allow a better grip when ascending or descending.
The rung material generally will be made out metal round
stock. With the assumption we are discussing portable lad-
ders, I believe you could argue the conformity of the hands
to the rungs or rails.
My suggestion would be to practice the three general
guidelines:
sh.nsc.org
sh.07.12.letters.indd 11
Letters
• Three-point contact at all times
• Belt buckle within the rails of the ladder at all times
• Never carry tools or materials while ascending or descend-
ing the ladder
Randy Billingsley
EH&S Officer
At our location we have both fixed ladders and portable
ladders for maintenance crews.
I think about which to use each time I climb a ladder.
Some side rails are too wide for a small hand to get a
good grip. Others require an awkward posture either due
to width or depth. Other times the rungs have tread grips
which would be uncomfortable or if the environment is dirty
may be coated in a residue from the shoes of the previous
trip. Without a standard design for all ladders I agree with
the statement that either is acceptable. I would rather the
climber have the best grip than one that is prescribed by
a safety professional in an office who never climbed their
ladder.
Tim McDaniel
Navistar
Springfield, OH
I spent five years in the cable industry training, coach-
ing and correcting ladder handling techniques that we felt
were the safest to our crews. We always recommended,
suggested and at times demanded that the side rails be
used to ascend and descend the ladder. In our industry
the techs had to deal with mud, snow, ice and other debris
which would inevitably make the rungs of the ladder a haz-
ard to use as three points of contact. The side rails, how-
or ice. 
This practice is not how those in construction feel. I brought
in a consultant with years of construction experience, and he
was adamant that rungs be used at all times – until we took
him in the field on a muddy spring day and he saw what we
had to deal with. Then he changed his tune and agreed that
 
What this really boils down to is arguing over the standard
to use when we just need to concentrate on what the objec-
tive is. Regardless of if you prefer (or strongly believe) that
rungs should be used – or not – the objective is for the worker
to be safe and as long as that happens it truly should not mat-
ter how you achieve that objective. 
Aaron Lilach, CSM
Owner, Account Consultant
Assured Services LLC
Fond Du Lac, WI
Safety+Health | July 2012 11
6/11/12 3:30 PM
 Letters
Letter SPOTLIGHT
Progress needed on preventing backover incidents
I just read Kyle W. Morrison’s article “Reducing backover
incidents” in the June issue of Safety+Health (p. 56) and
wanted to say, fantastic job on the coverage.
What I found a little ironic was
that the same issue featured an
article about the difficulty OSHA Reducing
faces in trying to promulgate
CONCERNS
GROW OVER THE
a new standard – and truth be
HIGH NUMBER
OF WORKER
DEATHS
known, if they ever needed one,
it’s for backing vehicles.
I co-presented with David
Fosbroke on this same topic at
a safety conference for Roads &
Bridges a couple of years ago,
and served with David on the
56 Safety+Health | June 2012
American Road & Transportation sh.06.12.backoverinjuries.indd 56
Builders Association Safety Committee when we were look-
ing at developing recommendations for an internal traffic
control plan. He and NIOSH are doing yeoman’s work on
the issue, but it’s all advisory. In his article, Kyle nailed it
correctly about the State Plans coming up with their own
standards, and mercifully Virginia has done just that. Every-
one recognizes the danger. There is just such a crushing
burden for OSHA to move on this issue, it’s heartbreaking.
Rungs vs. rails: The debate continues
The Editor’s Note in the May issue of Safety+Health asked readers
to share their opinions on holding the side rails of a ladder versus
holding the rungs. S+H shared some of those responses in the July
issue; more responses are below.
I was in the safety field for nearly 40 years (retired last
year) and worked for the U.S. Air Force, Bureau of Indian
Affairs, OSHA and several companies in private industry.
During my career I taught many ladder-safety courses,
where the subject of using the side rails versus using the
rungs has come up. It’s the old adage of are you a rung-ie or
a rail-ie? The only plausible answer is, “It depends.”
The goal is to get to the top or bottom of the ladder as
safely as possible. Therefore, it is my contention/opinion
that whatever method is comfortable for you, you should
use. However, with that in mind, there are many cases
where you will have to use both the rungs and side rails
to safely climb a particular fixed ladder, such as a step-
through ladder on which all you have to hold onto when
accessing or exiting the top landing are the side/hand rails
that extend above the landing. Some would contend that
this area is not part of the climb, but I do not agree. Some
of the newer ladders have incorporated horizontal grab
10 Safety+Health | August 2012
sh.08.12.letters.indd 10
And the backing safety issue is not confined to construc-
tion. Back in March, an article in USA Today talked about
the epidemic of backing accidents to motorists, notably in
their own driveways, often with
horrific consequences. Interest-
backover incidents ingly, automakers have seized on see behind the vehicle while backing up. Under federal stan-
C
By Kyle W. Morrison, senior associate editor
the opportunity and are offer-
dards, neither the driver nor the worker outside the vehicle
huck Stribling was a teen learning how guiding the driver has a responsibility to maintain visual
to drive when he experienced the sick- contact with one another, and the driver is not required to
ening feeling of backing his vehicle over stop when contact is lost. Additionally, the driver does not
something. “When I heard that thud, there have to exit the vehicle to check behind it before backing up.
was a pit in my stomach,” he said. But the hazard of backing operations is nothing new on
ing increasingly sophisticated
Luckily, the “victim” was only a garbage worksites. So why is the issue gaining more attention?
can. But it highlighted to Stribling, now the Kentucky Labor Part of the reason is because other well-known hazards,
Cabinet’s occupational safety and health federal-state coor- such as flaggers being struck by passing vehicles, are being
dinator, what drivers at worksites must feel when they inad- minimized, and the reality of the backing hazard is coming
vertently back a vehicle or piece of equipment over someone. into better focus.
backing safety systems on their
“I can only imagine being a driver on a construction site, NIOSH statistician Dave Fosbroke has examined road
feeling that bump and the horror construction zone fatality data for
that has to fill you with,” he said. “I can only imagine being a more than 10 years. He first worked
It is a horror too many workers driver on a construction site, on motor vehicle fatalities on con-
face, according to some stake- struction sites until he was asked
feeling that bump and the
holders. Between 2005 and 2010, about equipment run-overs. He
high-end vehicles. The message
more than 350 workers were horror that has to fill you with.” found very little examination into
killed as a result of vehicles or Chuck Stribling, Kentucky Labor Cabinet the issue, as almost all of it was
equipment backing up. This data focused on traffic safety.
has prompted OSHA to examine whether a rule is needed to Looking at the data, he discovered that almost as many
regulate backing procedures on worksites. workers died after being run over as those struck by motor-
needs wider dissemination –
On March 29, OSHA opened the record for public comment, ists. Unfortunately for workers, however, more attention
requesting information on what actions – if any – the agency is paid to motorists and work zone safety than to safety
could take in reducing injuries and deaths from back-over- within a work zone.
related incidents. (At press time, the record is scheduled to “More recently, there are more people run over by con-
close on June 27.) struction equipment than by motorists,” Fosbroke said.
It is not certain whether an OSHA standard could help
starting with high school driver’s
reduce fatalities and the untold numbers of injuries that may Sound the alarm
be occurring from backing operations, but most experts agree One of the few federal requirements addressing backing
employers can take steps to reduce the risk on worksites. operations is the use of a back-up alarm – the familiar
beeping sound heard whenever a dump truck or forklift
A ‘disturbingly consistent’ hazard is in reverse. However, that warning device is for workers
ed, and going north from there.
As director of Virginia’s Division of Legal Support within the on the ground, not for the driver. And even for workers
Department of Labor and Industry, Jay Withrow’s responsi-
bilities include reviewing every fatal incident case fi le before Feature at a Glance
a decision is made on whether or not to issue a citation. Concerns are growing about the high number of deaths due to
All photos: Cathy Morrison, staff photographer,
vehicles or equipment backing over workers. An OSHA standard for
During his 27 years with the department, Withrow has
regulating backing operations does not exist, but employers can take
discovered that many back-over fatality cases have similar
Missouri Department of Transportation
proactive steps to reduce the hazard.
But I’m very happy you folks
scenarios: The driver either did not know anyone was behind
the vehicle, or the driver lost sight of someone he or she knew Key points
was behind the vehicle. Either way, the driver continued • The use of spotters, good communication and an internal traffic
backing up and did not stop until a bump was felt. control plan can minimize the risk of a back-over incident.
“It’s disturbingly consistent when you read the interviews • All drivers should be trained to stop their equipment immediately if
they lose sight of their spotter, experts recommend.
with the drivers,” Withrow said of the fatality scenarios.
decided to get the issue out into
• Two State Plan states have a standard to regulate backing opera-
Vehicles and equipment – especially larger ones – have tions, and OSHA is investigating the possibility of a federal standard.
blind areas that make it impossible for operators to fully
sh.nsc.org sh.nsc.org Safety+Health | June 2012 57
5/15/12 9:25 AM sh.06.12.backoverinjuries.indd 57
plain view. Now if we could only 5/11/12 4:06 PM
get the regulatory guys talking to the scientists and statisti-
cians, we might make some better progress.
Nice job – please keep it going!
John J. Meola, CSP, ARM
Occupational Safety & Health Manager
Louis Berger Group
Richmond, VA
bars in this area. Many ladders have very coarse anti-slip
material on the rungs and/or are constructed with metal
that looks like standard re-bar (legal, if of the correct type
material), or other type of material that is not conducive to
a good grip. This makes it very uncomfortable and some-
times more dangerous to climb using its rungs, even when
using gloves. There are many other factors to take into con-
sideration when climbing while using the rungs, such as
dirt, grease or other substances left on the rung by other
climbers. If side rails were not meant to be used for climb-
ing, why then does the ANSI B14 series standard require
that the side rails be constructed so that a climber can get
a “power grip” on them, but does not mention require-
ments for a power grip for the rungs, only a minimum size
or equivalent in strength?
Over many years of knowing Dr. Ellis, he and I have had
more than one conversation about rails versus rungs, and
although I respect his opinion and professional experience,
let’s just say we agree to disagree on the subject.
Richard A. Eichel
Retired safety professional and prior CSP, OHST and CHST
Manchester, TN
sh.nsc.org
7/10/12 1:50 PM

As a fire academy director and fire service instructor, I read
with great interest your recent articles on portable ground
ladders. While I agree with the 20 steps and the opinion
offered by J. Nigel Ellis, I would also offer the following tips:
1. On extension ladders, the rope (halyard) must be inspected
for damage or wear. Natural fibered rope should be replaced
as this rope degrades from exposure to water and ultravio-
let light.
2. Climbers must perform a visual check to ensure that the
locks (pawls, dogs) are fully engaged around the rung before
climbing onto an upper section.
3. The fire service teaches that unless otherwise directed by
the manufacturer, both aluminum and fiberglass ladders
are to be raised with the upper section (fly) on the outside.
4. Ladders should be inspected following each use and
cleaned according to the manufacturer’s recommendations.
5. When ascending a ladder with the intent to transition onto
a roof, the following issues are worth mentioning:
• Has the climber placed the tip against a parapet wall? If
so, he or she may have difficulty transitioning from the
ladder to the flat roof.
• Prior to committing oneself to the roof, the climber
should “sound” the roof to check for integrity.
• The fire service teaches a minimum of five rungs extended
above the roofline. This is done to aid the climber from
transitioning from ladder to roof and vice versa.
Robert V. Hill Sr.
Director, Gloucester County Fire Training Academy
Clarksboro, NJ
With humor, I read your “Ladder safety, part 2” and was
surprised at the instruction from Dr. Ellis regarding hold-
ing the rungs when ascending/descending ladders. I did
some quick Internet searching and found the following (as
one example) from Oregon OSHA on page 13 stating the
ladder should be held at the side rails: www.cbs.state.or.us/
osha/pdf/pubs/3083.pdf.
Although gripping the rungs on an extension ladder might
be a useful suggestion, I would find  it difficult to grip the
square wide rungs on a step ladder such as my Werner 6-foot
home ladder. I was also surprised that he suggested using
a backpack to carry tools up or down from a ladder. While
a useful suggestion, I wonder how someone would then
retrieve the tools while maintaining three points of contact on
the ladder (a standard safety practice discussed in step 11).
I guess I was surprised at how adamant these suggestions
sounded and think we are trying to “split atoms.” Most com-
panies just suggest maintaining a firm grip with three points
of contact.
Rob Wilmot, CSP
Batesville, IN
sh.nsc.org
sh.08.12.letters.indd 11
Letters
I was intrigued by your recent article and follow-up notes
about ladder safety. As I read the correction found in the
“Letters” section, I noticed that the most prominent reason
for choosing rungs was because the hand would slip if a fall
actually occurred. Dr. Ellis’ paper thoroughly documents this
fact. (Although I have to ask: Since when are arms an accept-
able means of fall protection equipment?) What we should
be most concerned about is not what happens post-incident
but what happens pre-incident. How can we prevent the lad-
der fall in the first place?
We must first consider stability. Stability is a state in which
the body is balanced. It is very important to stay balanced
while using a ladder. Becoming unbalanced due to a trip,
slip or improper body movement can have some distress-
ing, often disastrous, results. Improper body movements are
related to how and where a person puts their hands. Hand
placement on most ladders comes down to two choices: side
rails or rungs.
Side rails should be avoided, not only because of the post-
incident deviation and slipping as mentioned by Dr. Ellis, but
because it can cause unnecessary balance problems. Usu-
ally, rungs are attached directly to the side rails. As workers
move their hand up or down the rail they will encounter other
rungs, resulting in a constant battle and limiting stability.
Side rails are sometimes a little thicker than what is recom-
mended for a good power grip.
Rungs are not the ideal handle. If rungs are used, the slip
factor may be lessened but not eliminated. Ladder rungs
should definitely come with a gripped, nonslip surface, but
for some people grabbing and supporting some weight on
this gripped surface is uncomfortable. Gloves could be man-
dated. However, this will only increase management over-
sight responsibilities while decreasing dexterity.
In order to use the rungs, a worker’s hand must let go,
thus there are not three points of contact at all times. I
have even seen workers almost fly up the ladder using this
method. They are basically relying on two points of contact.
The more points of contact the more stability the worker
will have.
Due to these concerns, it is reasonable to conclude that
neither side rails nor ladder rungs are the best choice. Hand-
rails are the best option. Handrails prevent falls by means of
stabilization. They are not meant to stop a fall in progress,
although they could help if an incident did occur. We find
handrails on stairways of all angles.
As the angle exceeds 50 degrees, they become ship’s lad-
ders and handrails are still used. If handrails are used for both
stairs and ship’s ladders, why aren’t they used for the more
dangerous ladder? Side rails are there to provide support
and framework.
Rungs are for feet. Handrails are for hands.
Josh Edwards, OHST
Safety+Health | August 2012 11
7/12/12 8:27 AM