Ladder Safety Part 1: Three Points of Contact
It is a method that has been practiced for decades and is one of the simplest and most cost-effective ways to prevent falls. It’s a method that can be used across industries, including healthcare, manufacturing, construction, and transportation.
In case you haven’t guessed yet, I’m referring to the three points of contact (control) method, in which an individual remains in contact and in control, utilizing at least three of four limbs -- two feet and one hand or two hands and one foot -- while ascending or descending to any walking or working surface.
Let’s point out the obvious: The three points of control method isn’t new or groundbreaking and has been communicated as a “best practice” for some time. Maintaining three points of control with your walking and working environment, for example ladder or handrail, ensures maximum contact to increase stability and improve ability to respond should a slip, trip, or other event occur.
Preventing falls should be easy, right? Stay aware, pick up your feet, hold on to those handrails, use the right ladder(s) for the job … the list goes on. Yet falls continue to be one of the most frequent causes of workplace fatalities and serious injuries year after year.
In 2020, the US Bureau of Labor and Statistics reported that falls resulted in 805 worker fatalities. An additional 210,000+ workers (National Safety Council Injury Facts 2020) lost one or more workdays due to severe injury from a fall. While OSHA has established various heights where fall prevention controls are required, the reality is that all falls, regardless of height, occur due to the failure to recognize and mitigate basic safety hazards.
OSHA has recommended three points of contact as best practice. However, with the 2017 update, it is now mandated as general requirements for all ladders.
While ascending and descending, the newest regulation requires employees to:
- Face the ladder when climbing up or down it [1910.23(b)(11)];
- use at least one hand to grasp the ladder when climbing up and down it [1910.23(b)(12)];
- do not carry any object or load that could cause the employee to lose balance and fall while climbing up or down the ladder [1910.23(b)(13)]; and
- use a “firm grasp” (as defined by OSHA) at all times, specifically forbidding “sliding contact” techniques [preamble].
Furthermore, OSHA clarified that the employee should carry small items such as hand tools in pouches or on belt loops to ensure full control while using ladders, and that “the employee’s focus and attention while climbing up and/or down a ladder should be on making a safe ascent or descent and not on transporting items up and down the ladder” (55 FR 47682).
Prior to 2017, ANSI’s consensus standard 1264.1, allowed for forward facing descent (facing away from ladder) for mobile ladders and work platforms with a climbing angle of 50 degrees or less assuming three points of control are maintained. Interestingly, when OSHA updated their regulatory text, it did not adopt this specific excerpt. Therefore, forward-facing descent is no longer acceptable, regardless of climbing angle [1910.23(b)(11)]. What this means for employers and employees is that unless materials, containers, boxes, tools, etc., can be carried safely with a single hand, another method of moving materials must be utilized.
In summary, OSHA expects and requires that employers ensure the use of three points of contact on ladders and mobile platforms. This may not be possible in all situations; therefore, other methods of material handling should be used, or fall protection must be utilized.
MEMIC policy holders have access to ladder training materials, safety rules, and an inspection checklist, on the Safety Director. Also look for MEMIC webinar: Ladder Safety, available in English and Spanish.
Check the blog next week for Ladder Safety Part 2: Does your Ladder Safety Training Get High Marks?
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