COMPLETE REVISION

July 2018

Structural

PIP STE05501
Fixed Ladders Design Guide
 PURPOSE AND USE OF PROCESS INDUSTRY PRACTICES

In an effort to minimize the cost of process industry facilities, this Practice has
been prepared from the technical requirements in the existing standards of major industrial
users, contractors, or standards organizations. By harmonizing these technical requirements
into a single set of Practices, administrative, application, and engineering costs to both the
purchaser and the manufacturer should be reduced. While this Practice is expected to
incorporate the majority of requirements of most users, individual applications may involve
requirements that will be appended to and take precedence over this Practice.
Determinations concerning fitness for purpose and particular matters or application of the
Practice to particular project or engineering situations should not be made solely on
information contained in these materials. The use of trade names from time to time should
not be viewed as an expression of preference but rather recognized as normal usage in the
trade. Other brands having the same specifications are equally correct and may be
substituted for those named. All Practices or guidelines are intended to be consistent with
applicable laws and regulations including OSHA requirements. To the extent these
Practices or guidelines should conflict with OSHA or other applicable laws or regulations,
such laws or regulations must be followed. Consult an appropriate professional before
applying or acting on any material contained in or suggested by the Practice.

This Practice is subject to revision at any time.

© Process Industry Practices (PIP), Construction Industry Institute, The University of Texas
at Austin, 3925 West Braker Lane (R4500), Austin, Texas 78759. PIP Member Companies
and Subscribers may copy this Practice for their internal use. Changes or modifications of any
kind are not permitted within any PIP Practice without the express written authorization of
PIP. Authorized Users may attach addenda or overlays to clearly indicate modifications or
exceptions to specific sections of PIP Practices. Authorized Users may provide their clients,
suppliers and contractors with copies of the Practice solely for Authorized Users’ purposes.
These purposes include but are not limited to the procurement process (e.g., as attachments to
requests for quotation/ purchase orders or requests for proposals/contracts) and preparation
and issue of design engineering deliverables for use on a specific project by Authorized
User’s client. PIP’s copyright notices must be clearly indicated and unequivocally
incorporated in documents where an Authorized User desires to provide any third party with
copies of the Practice.

PUBLISHING HISTORY
October 2012 Issued
January 2017 Technical Correction
July 2018 Complete Revision

Not printed with State funds

 COMPLETE REVISION
July 2018

Structural

PIP STE05501
Fixed Ladders Design Guide
Table of Contents
5.3 Considerations for Compliance
1. Scope ..........................................3 with OSHA Fall Protection
Regulations for Fixed Ladders ..... 15
2. References .................................3 5.4 Ladder Safety System
2.1 Process Industry Practices .............3 Requirements ............................... 17
2.2 Industry Codes and Standards .......3 5.5 Personal Fall Arrest System
2.3 Government Regulations ................4 Requirements ............................... 17

3. Definitions ..................................4 6. Inspection, Tagging, Use and

Training Requirements ........... 17
4. Ladder Design............................6
4.1 General ...........................................6 7. Contract Documents ............... 17
4.2 Ladder Lengths ...............................7
4.3 Platform Access ..............................8 8. Fabricator Shop Drawings
4.4 Ladder Cages .................................9 Review ...................................... 19
4.5 Ladder Supports and Guides ..........9
4.6 Ladder Rails ................................. 10 9. Typical Details ......................... 20
4.7 Ladder Rungs .............................. 10
4.8 Ladder Pitch ................................. 11 Table 1 - Thermal Expansion Data
4.9 Design Loads ............................... 12
4.10 Allowances for Temperature (U.S. Customary Units) ........... 21
Variation for Vertical Vessels ....... 13
4.11 Ladder Pads ................................. 14 Table 1M - Thermal Expansion Data
4.12 Ladder Clearances ....................... 14 (Metric Units) ........................... 23

5. Ladder Fall Protection ............. 14 Appendix A - Commentary on

5.1 General ........................................ 14 Interpretation of OSHA Regulations
5.2 Fixed Ladders Extending more 29 CFR Part 1910 Subpart D, Section
than 24 feet (7.3 m) above a Lower
Level............................................. 15
1910.28(b)(9) ................................. 23

Process Industry Practices Page 1 of 26

Drawings
STE05501-01 – Side Elevation
STE05501-02 – Side-Step Ladder at Top
STE05501-03 – Through Ladder at Top
STE05501-04 – Through Ladder Top Connection
Details
STE05501-05 – Ladder Base at
Structure/Platform or Horizontal Vessel
STE05501-06 – Ladder Base at Vertical Vessel
STE05501-07 – Side-Step Ladder Support
Connection to Vertical Vessel
STE05501-08 – Side-Step Ladder Support
Connection to Structure/Platform
STE05501-09 – Through Ladder Support
Connection to Structure/Platform
STE05501-10 – Ladder Guide Connection to
Vertical Vessel
STE05501-11 – Laddder Guide Connection to
Structure/Platform
STE05501-12 – Optional Cage – Side Elevation
STE05501-13 – Optional Cage – Intermediate
Access with Side-Step Ladder
STE05501-14 – Optional Cage – Hoop Details
STE05501-15 – Optional Cage – Top Hoop
Connections to Guard Post
STE05501-16 – Optional Cage – Miscellaneous
Details
STE05501-17 – Optional Cage at Elevated
Platform
STE05501-18 – Continuous and Multiple-Section
Ladders

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1. Scope
This Practice provides design guidelines for typical OSHA-regulated fixed ladders, ladder safety
systems/personal fall arrest systems and cages as specified and detailed for fabrication in
PIP STF05501 for open structures, miscellaneous platforms, and vessels for regular operational
access and egress. Typical detail drawings for design are provided that describe ladder and cage
details, platform access configurations, support and guide connections, ladder location details,
and ladder clearances for side step and through ladder types.
The intention of this Practice is to inform structure/platform engineers of OSHA regulations
regarding fixed ladders and discuss some practical issues that may arise. Interpretations of the
OSHA regulations are the responsibilities of the owner and engineer of record.

2. References
Applicable parts of the following Practices, industry codes and standards, and government regulations
shall be considered an integral part of this Practice. The edition in effect on the date of contract award
shall be used, except as otherwise noted. Short titles are used herein where appropriate.

2.1 Process Industry Practices (PIP)

 PIP ADG009 - Guideline for Increasing Global Application of Practices
– PIP CVC01017 - Plant Site Data Sheet
– PIP CVC01018 - Project Data Sheet
– PIP STC01015 - Structural Design Criteria
– PIP STE05520 - Guards and Handrails Design Guide
– PIP STF05501 - Fixed Ladders Fabrication Details
– PIP STF05520 - Pipe Guards and Handrails Fabrication Details
– PIP STF05521 - Angle Guards and Handrails Fabrication Details
– PIP STF05535 - Vessel Circular Platform Fabrication Details
– PIP STI03310 - Concrete Typical Details
– PIP STS05120 - Structural and Miscellaneous Steel Fabrication Specification
2.2 Industry Codes and Standards
 American Institute of Steel Construction (AISC)
– ANSI/AISC 303-16 - Code of Standard Practice for Steel Buildings and Bridges
 American National Standards Institute, Inc. (ANSI)
– ANSI-ASC A14.3-2008 - American National Standard for Ladders – Fixed –
Safety Requirements
 American Society of Civil Engineers (ASCE)
– ASCE/SEI 7-10 - Minimum Design Loads for Buildings and Other Structures
 National Fire Protection Association (NFPA)
 NFPA 101-12 - Life Safety Code
 NFPA 101-15 - Life Safety Code

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Comment: In this Practice both versions of the code are referred to as “NFPA 101”
or “NFPA” and are used in reference to provisions for guards for which both
versions are virtually identical.
2.3 Government Regulations
The following government document has been used as a reference in the development of
this Practice.
 U.S. Department of Labor (DOL) - Occupational Safety and Health Administration
(OSHA)
– Regulations 29 CFR 1910 Subpart D - Walking-Working Surfaces and Subpart I –
Personal Protective Equipment (Amended) - Final Rule Published in Federal
Register, Volume 81, No. 223, on November18, 2016 (referred to as “OSHA” in
this Practice)

3. Definitions
This Practice uses the same terminology as AISC, OSHA and NFPA. After each definition, the
source document is indicated in parentheses. “(AISC)” refers to ANSI/AISC 303-16. “(OSHA)”
refers to OSHA Regulations 29 CFR 1910 Subpart D and Subpart I. “(NFPA)” refers to NFPA
101-12 or NFPA 101-15 as applicable. “(PIP)” indicates PIP definitions not specifically provided
by AISC, OSHA or NFPA.

anchorage: A secure point of attachment for equipment such as lifelines, lanyards, deceleration
devices, and rope descent systems (OSHA)

cage: An enclosure mounted on the side rails of a fixed ladder or fastened to a structure behind the
fixed ladder that is designed to surround the climbing space of the ladder. A cage also is called a
‘‘cage guard’’ or ‘‘basket guard.’’ (OSHA)

carrier: The track of a ladder safety system that consists of a flexible cable or rigid rail attached to
the fixed ladder or immediately adjacent to it (OSHA)

contract documents: Any and all documents, including codes, studies, design documents,
specifications, sketches, Practices, and data sheets, that purchaser or engineer of record has
transmitted or otherwise communicated, either by incorporation or reference, and made part of the
legal contract agreement or purchase order between purchaser and structure/platform fabricator,
ladder fabricator and/or vessel manufacturer (PIP)

design documents: The design drawings, or where the parties have agreed in the contract
documents to provide digital model(s), the design model. A combination of drawings and digital
models also may be provided. (AISC)

design drawings: The graphic and pictorial portions of the contract documents showing the
design, location and dimensions of the work. These documents generally include, but are not
necessarily limited to, plans, elevations, sections, details, schedules, diagrams and notes. (AISC)

design model: A dimensionally accurate 3D digital model of the structure that conveys the
structural steel requirements given in Section 3.1 [of ANSI/AISC 303-16] for the building [or
structure] (AISC)

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engineer of record: Purchaser’s authorized representative with overall authority and responsibility
for engineering design, quality, and performance of civil works, structure, foundations, materials,
and appurtenances described in contract documents. Engineer of record shall be licensed as defined
by laws of the locality in which the work is to be constructed, and be qualified to practice in the
specialty discipline required for the work described in contract documents. (PIP)

fabricator shop drawings: Drawings produced by a fabricator that transfer information from
design documents and other contract documents into accurate, detailed dimensional information
to be used for fabrication of ladders and structural steel (PIP)

fixed ladder: A ladder with rails or individual rungs that is permanently attached to a structure,
building, or equipment. Fixed ladders include individual-rung ladders, but not ship stairs, step
bolts, or manhole steps. (OSHA)

guard: A vertical protective barrier erected along exposed edges of stairs, balconies, and similar
areas (NFPA)

Comment: The term “guardrail system” used by ASCE and OSHA is considered by PIP to be
equivalent to the term “guard” used by NFPA. The typical railing around the
perimeter of platforms on open process structures, for example, is referred to in
NFPA and this Practice as a "guard."

guard fabricator: Party responsible for providing fabricated guards for platforms in accordance
with contract documents. The term guard fabricator shall apply also to guard fabricator’s
subcontractor(s) and/or vendor(s) (see PIP STE05520). (PIP)

ladder fabricator: Party responsible for providing fabricated ladders in accordance with contract
documents. The term ladder fabricator shall apply also to ladder fabricator’s subcontractor(s)
and/or vendor(s). (PIP)

ladder safety system: A system designed to eliminate or reduce the possibility of falling from a
ladder. A ladder safety system usually consists of a carrier, safety sleeve, lanyard, connectors,
and body harness. Cages and wells are not ladder safety systems. (OSHA)

lower level: A surface or area to which an employee could fall. Such surfaces or areas include,
but are not limited to, ground levels, floors, roofs, ramps, runways, excavations, pits, tanks,
materials, water, equipment, and similar surfaces and structures, or portions thereof. (OSHA)

maximum intended load: The total load (weight and force) of all employees, equipment, vehicles,
tools, materials, and other loads the employer reasonably anticipates being applied to
a walking-working surface at any one time (OSHA)

owner: Party who has authority through ownership, lease, or other legal agreement over site,
facility, structure, platform, vessel or project wherein ladders will be used (PIP)

personal fall arrest system: A system used to arrest an employee in a fall from a walking-working
surface. It consists of a body harness, anchorage, and connector. The means of connection may
include a lanyard, deceleration device, lifeline, or a suitable combination of these. (OSHA)

personal fall protection system: A system (including all components) an employer uses to provide
protection from falling or to safely arrest an employee’s fall if one occurs. Examples of personal

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fall protection systems include personal fall arrest systems, positioning systems, and travel
restraint systems. (OSHA)

purchaser: Party who awards contract to structure/platform fabricator, ladder fabricator and/or
vessel manufacturer. Purchaser may be owner or owner’s authorized agent. (PIP)

side-step ladder: A type of fixed ladder that requires an employee to step sideways from it in
order to reach a walking-working surface, such as a landing (OSHA)

structure/platform engineer: Engineer that performs design of structures/platforms, including

ladders that connect to structures/platforms. Structure/platform engineer may also perform design
of ladders that connect to vessels if design of ladder support and guide connections is validated by
a vessel engineer. (PIP)

structure/platform fabricator: Party responsible for providing fabricated structural and

miscellaneous steel in accordance with contract documents. The term structure/platform fabricator
shall apply also to structure/platform fabricator’s subcontractor(s) and/or vendor(s). (PIP)

through ladder: A type of fixed ladder that allows the employee to step through the side rails at
the top of the ladder to reach a walking-working surface, such as a landing (OSHA)

travel restraint system: A combination of an anchorage, anchorage connector, lanyard (or other
means of connection), and body support that an employer uses to eliminate the possibility of an
employee going over the edge of a walking-working surface (OSHA)

vessel engineer: Engineer that performs design of vessels, including ladders that connect to
vessels. Alternatively, vessel engineer may validate design of ladder support and guide
connections to vessels for ladders that are designed by a structure/platform engineer. (PIP)

vessel manufacturer: Party responsible for providing manufactured vessels in accordance with
contract documents. The term vessel manufacturer shall apply also to vessel manufacturer’s
subcontractor(s) and/or vendor(s). (PIP)

well: A permanent, complete enclosure around a fixed ladder (OSHA)

4. Ladder Design
4.1 General
4.1.1 Fixed ladders should be designed in accordance with OSHA Regulations 29 CFR
1910 Subpart D. Revisions to the OSHA regulations which were published in the
Federal Register Volume 81, No. 223 and took effect on January 17, 2017 impact
many aspects of ladder design, installation and use. The impact of the revised
OSHA regulations on ladder design is discussed in this section. The most
significant impact is in the area of ladder fall protection which is discussed in
Section 5 of this Practice.
4.1.2 This Practice provides guidelines for design of fixed ladders as mandated by
OSHA regulations. ANSI-ASC A14.3-2008, which is a national standard, may
also be used as a reference that provides guidelines for design of fixed ladders,
however, OSHA regulations are mandated by the federal government and take
precedence over ANSI-ASC A14.3-2008. Fixed ladder design and fabrication as
represented in this Practice and PIP STF05501 are based on OSHA regulations

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and standard industry practice and do not necessarily address or adhere to any
provisions of ANSI-ASC A14.3-2008.
4.1.3 The revised OSHA regulations have been written to be more performance-based
and less prescriptive than previous OSHA regulations. As a result, many of the
provisions are based on the intended use of the fixed ladder rather than specific
prescriptive requirements. The revised OSHA regulations also provide more
design options for employers to meet the regulations. PIP has intended for
options in some cases to be left to the owner to decide and in other cases to be
based on common industry practice established by details used in previous
versions of PIP STE05501 and PIP STF05501.
4.1.4 Fixed ladders and ladder safety systems/personal fall arrest systems should be
designed in accordance with criteria provided by owner in PIP CVC01017 and
PIP CVC01018, as applicable.
4.1.5 Metric units provided in this Practice and PIP STF05501 are based on
PIP ADG009. Units in centimeters referenced from OSHA have been converted
to millimeters for consistency with units referenced from other sources and
standard metric units as indicated in PIP ADG009.
4.2 Ladder Lengths
4.2.1 OSHA does not require fall protection on fixed ladders that extend 24 ft (7.3 m)
or less above a lower level.
4.2.2 Ladders that extend more than 24 ft (7.3 m) above a lower level are required to
meet OSHA fall protection requirements. Refer to Section 5.2.
4.2.3 Ladders equipped with a personal fall arrest system or ladder safety system are
not limited in length, but the personal fall arrest system or ladder safety system is
required to provide protection throughout the entire vertical length of the ladder
including all ladder sections, and the ladder is required to have rest platforms
provided at maximum intervals of 150 feet (45.7 m).
4.2.4 During the 20-year extended compliance period (see Sections 5.2.2 and 5.2.3),
ladder sections with cages or wells are required to be offset from one another and
to have landing platforms provided at maximum intervals of 50 feet (15.2 m). This
provision no longer applies once the ladder is furnished with a ladder safety or
personal fall arrest system.
4.2.5 Side rails for through or side-step ladders are required to extend 42 inches
(1100 mm) minimum above top of access level or landing platform. PIP
standardizes on a 48-inch (1200-mm) extension to allow for another rung to
better facilitate attachment of ladder safety systems or personal fall arrest
systems to multiple ladder rungs.
4.2.6 PIP recommends that ladders longer than 55 ft (16.8 m) in total length be
fabricated in segments, with the maximum overall length of each segment
approximately 55 ft (16.8 m) for practical reasons. Longer fabricated segments
require special fabrication, galvanizing and shipping considerations. Fabricated
segments may be left independent, with each segment independently supported
and a gap provided between segments. Refer to details shown on drawing
PIP STE05501-04. See Section 4.4.4 for segmented ladders with cages.

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4.2.7 For ladders attached to vertical vessels or other applications where temperature
variation is a concern, PIP recommends that continuous ladders be avoided and
ladder sections be offset, with side-step access to landing platforms provided at
50-ft (15.2-m) maximum intervals. See Sections 4.5.2 and 4.10 for further
discussion on this topic.
4.3 Platform Access
4.3.1 A ladder with side-step access at the top platform serviced by the ladder is the
preferred configuration by common industry practice. Through ladders could create
clearance issues with ladder safety systems and should be avoided if possible.
4.3.2 Side-step access between a continuous ladder and an intermediate platform along its
length is not specifically prohibited by OSHA. The situation is not appreciably different
from stepping onto or off of the top of a side-step ladder. Some owners, however, may
prohibit intermediate access because of concerns about an employee stepping out onto
the ladder from an intermediate platform and interfering with another employee
climbing the ladder, and instead require a break in the ladder at each intermediate
platform, with separate offset ladder sections to continue up or down.
4.3.3 Self-closing double-bar safety gates, in accordance with OSHA, are required to be
provided at openings in platform guards for all platforms serviced by the ladder.
OSHA requires safety gates to provide the same protection as a platform guard
when the safety gate is in the closed position with the exception that a toe plate is
not required at the opening at a ladder. See PIP STE05520 for further discussion.
4.3.4 Some owners may have a preferred manufacturer and type of safety gate to be
used for their facility that should be specified in contract documents accordingly.
Safety gates should be supplied by guard fabricator.
4.3.5 The location of the safety gate hinges relative to the ladder orientation as well as
minimum required swing angle of the safety gate should be selected by
structure/platform engineer to provide adequate accessibility between ladder and
platform. At the top of side-step ladders, safety gate hinges should be located at
the back of the person using the ladder, for ease of use. Direction of swing should
be shown in design documents. Minimum required swing angle for safety gates
should be 90 degrees. The minimum required swing angle of safety gate should
be shown in design documents if greater than 90 degrees.
4.3.6 The mounting plate of most manufactured safety gates will extend into the clear
opening between guard posts at the ladder access, thus reducing the effective
clear opening in the guard system. This difference is required to be accounted for
in establishing the required face-to-face dimension between the guard posts.
4.3.7 At the top of through ladders, the effective clear opening in the guard system
should match the face-to-face dimension between the flared rails at the top of the
ladder. In accordance with OSHA, the dimension between the flared rails at the
top of a through ladder is required to be not less than 24 inches (610 mm) and not
more than 30 inches (760 mm), except when a ladder safety system is provided
on the ladder, the dimension must not exceed 36 inches (910 mm). If the safety
gate mounting gate encroaches into the opening in the guard system, the
dimension should be adjusted to provide an effective clear opening in the guard
system of not less than 24 inches (610 mm).

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4.3.8 At the top of side-step ladders, the effective clear opening in the guard system,
including the encroachment of the safety gate mounting plate, should not be less
than 18 inches (460 mm). PIP details provide for a 24-inch (610-mm) opening
between guard posts at side-step ladders, which is believed to be sufficient for
most manufactured safety gates, but this adequacy is required to be verified by
the structure/platform engineer.
4.4 Ladder Cages
4.4.1 As discussed in Sections 5.1 and 5.2 below, for new fixed ladders (installed on or
after November 19, 2018) extending more than 24 feet (7.3 m) above a lower
level, cages are no longer considered by OSHA to provide effective fall
protection and personal fall arrest system or ladder safety systems must be used
instead. OSHA does not mention the use of cages for fixed ladders extending
24 feet (7.3 m) or less above a lower level.
4.4.2 Although cages are no longer required on fixed ladders, this does not mean that cages
can no longer be provided, or that they no longer have any purpose. Cages may
provide psychological comfort to some users of ladders, especially on longer climbs.
In the event of emergency egress, it may not be practical for an employee to engage a
personal fall arrest system or ladder safety system and having a cage may provide
some protection to direct the fall of an employee to the base of a ladder for a fixed
ladder on an elevated platform. Some owners may still elect to provide cages on
longer fixed ladders or fixed ladders on elevated platforms in combination with a
personal fall arrest system or ladder safety system for these reasons.
4.4.3 The current OSHA regulations provide fewer specific prescriptive requirements
for cage construction than the previous OSHA regulations did. The details shown
on drawings PIP STE05501-12 through PIP STE05501-17 are in accordance with
previous OSHA regulations where current OSHA regulations do not provide
specific requirements. PIP still recommends use of these details if cages are used.
Some owners specify a larger inside radius for cages than shown in PIP details to
accommodate employees wearing heavy clothing in cold climates and/or air
packs in hazardous locations.
4.4.4 If cages are used on long ladders that are fabricated in segments, the cages should
also be fabricated in segments with the ladder (See Section 4.2.6). A 3-inch
(75-mm) hoop at the top of the lower cage segment and at the bottom of the
upper cage segment should be provided. Similar to the ladder rails, a gap should
be provided between cage segments. Refer to detail shown on drawing
PIP STE05501-16.
4.4.5 If a cage is used in combination with a personal fall arrest system or ladder safety
system (see Section 4.4.2 above), the cage is required by OSHA to not interfere
with the operation of the system.
4.5 Ladder Supports and Guides
4.5.1 Ladders should be supported at top and guided at bottom and along the length as
required based on the size and type of rails and unguided length criteria shown on
drawings PIP STE05501-01 and PIP STE05501-06. Having the support located
at top of ladder ensures that ladder rails will be loaded in tension and top rung
will remain level with the walking surface of the platform.

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4.5.2 Although OSHA permits continuous ladders of unlimited length provided they
have a personal fall arrest system or ladder safety system, caution is required
regarding ladders that attach to vertical vessels. It may not be practical to design
slotted guides that can accommodate the movement caused by temperature
differential between the vessel and ladder when the ladder is excessively long
(See Section 4.2.7).
4.5.3 The ladder support details shown in this Practice and PIP STF05501 are capable
of supporting a 150-ft (45.7-m) long ladder with cage, based on the load criteria
provided in Section 4.9.7 using a live load provided in Section 4.9.1.
4.5.4 Ladder support members, support connectors, and guide connectors to
structures/platforms should be located and designed by structure/platform
engineer and shown in design documents.
4.5.5 Ladder support members, support connectors, and guide connectors to vessels
should be located and designed by vessel engineer and shown in design
documents. Refer to Section 4.10 for additional guidance regarding clips on
vertical vessels with temperature variation.
4.6 Ladder Rails
4.6.1 OSHA does not provide prescriptive requirements for the shape or cross section
of ladder rails. ANSI-ASC A14.3-2008 indicates that various shapes may be used
for ladder rails that provide for a uniform gripping surface for the hands of
persons using the ladder, as long as the shape provides a power grip throughout
the length of climb. ANSI-ASC A14.3-2008 also recommends that ladder rails be
have a minimum cross section of 2-1/2 inches by 3/8 inches. The ladder rail
shapes and cross sections used by PIP are considered common industry practice
that meet these recommendations.
4.6.2 Selection of ladder rails by fabricator should be based on guide locations shown
in design documents and unguided length criteria shown on fabrication detail
drawing PIP STF05501-01, unless otherwise specified in contract documents.
4.6.3 Guides for ladder rails should be located and designed by structure/platform
engineer and/or vessel engineer based on using bar 2-1/2-inch by 3/8-inch ladder
rails wherever feasible. If it is not feasible to provide sufficient guides for bar
2-1/2-inch by 3/8-inch ladder rails, bar 3-inch by 3/8-inch or C3x4.1 ladder rails
should be used, in order of preference, based upon the feasibility of providing
sufficient guides.
4.7 Ladder Rungs
4.7.1 Ladder rung length of 1 ft-6 inches (460 mm) as specified in PIP STF05501 is
based on common industry practice and exceeds minimum required ladder rung
length of 1 ft-4 inches (410 mm) specified in OSHA. Rung length may be
reduced to minimum required by OSHA or increased at discretion of
structure/platform engineer, vessel engineer and/or owner. Increased rung lengths
may require a larger diameter rung based on design live load as prescribed in
Section 4.9 of this Practice.
4.7.2 Ladder rung of 3/4-inch (20-mm) diameter smooth bar as specified in
PIP STF05501 is based on common industry practice that was consistent with
prescriptive requirements for rungs in the previous OSHA regulations. The

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current OSHA regulations, which are performance-based, no longer have

prescriptive requirements for the rung but rather require ladders to be designed to
support the maximum intended load on the ladder. Ladder rungs specified in
PIP STF05501 are designed based on the requirements given in Section 4.9.1 of
this Practice, using a live load unit of 300 lb (1335 N). Assuming a 1 ft-6 inch
(460 mm) simply-supported span, the rungs are each capable of supporting a
maximum allowable live load unit of 315 lb (1400 N). See Section 4.9.3 for
cases in which the maximum intended live load exceeds this value and will
require a larger diameter rung.
4.7.3 Some owners specify the use of rungs that are corrugated, knurled, dimpled, or
have coatings, caps or other types of treatments that are intended to provide
additional slip resistance. Regardless of what is specified, it is important to provide
uniformity in the slip resistance throughout entire length of ladder. Regular
inspection of ladders and maintenance should be performed to ensure uniform slip
resistance has not been compromised over time due to dirt, wear or damage.
4.7.4 Ladder rung spacing of 1 ft-0 inch (300 mm) center-to-center as specified in
PIP STF05501 is based on common industry practice and within limits of 10 inches
to 14 inches (250 mm to 360 mm) specified by OSHA. Rung spacing may be reduced
or increased within limits specified by OSHA at discretion of structure/platform
engineer, vessel engineer and/or owner but are required to be uniform throughout the
length of ladder, however, consideration should be given to standardizing the rung
spacing throughout the facility.
4.7.5 It is not specifically stated in OSHA whether spacing between bottom rung and
base of ladder is also required to be uniform with rung spacing throughout length
of the rest of ladder.
4.7.6 Ladder pads for ladder bases at grade are designed to have a full 1 ft-0 inch
(300 mm) adjustability in height to accommodate uniform rung spacing of
1 ft-0 inch (300 mm) throughout length of the ladder including the bottom rung
to base of ladder. See Section 4.11 of this Practice for more information about
ladder pads.
4.7.7 For ladders with bases at elevated platforms, it is preferred to lay out platform
elevations such that height between platforms serviced by ladders are in even
1 ft-0 inch (300 mm) increments to accommodate uniform rung spacing of
1 ft-0 inch (300 mm) throughout length of ladder including the dimension from
the top of bottom rung to walking surface of platform. Where this is not feasible,
the dimension from the top of bottom rung to walking surface of platform may be
adjusted in accordance with common industry practice and criteria shown on
drawings PIP STE05501-01 and PIP STE05501-06.
4.8 Ladder Pitch
4.8.1 Based on Figure D-10 in OSHA, ladders are defined as having a pitch within a
range of 60 degrees and 90 degrees from horizontal. Fixed ladders having a pitch
in excess of 90 degrees from horizontal are specifically prohibited by OSHA.
4.8.2 Previous OSHA regulations classified ladders having a pitch within a range of
75 to 90 degrees as “standard” and ladders having a pitch within a range of 60 to
75 degrees as “substandard.” The current OSHA regulations do not make these

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distinctions but PIP still considers it good practice to limit the pitch of fixed
ladders to within a range of 75 to 90 degrees from horizontal.
4.8.3 Details shown in drawings in this Practice and fabrication details shown in
drawings in PIP STF05501 are intended only for ladders with a pitch of
90 degrees from horizontal. If a ladder is required with a different pitch,
additional fabrication details should be provided in an addendum to
PIP STF05501 or shown in design documents.
4.9 Design Loads
4.9.1 Current OSHA regulations no longer provide prescriptive load criteria for fixed
ladders, stating instead that they be designed to support their maximum intended
load. ASCE/SEI 7-10 provides prescriptive live load criteria for fixed ladders.
Specifically, ASCE/SEI 7-10 requires that fixed ladders be designed for a
minimum vertical concentrated live load of 300 lb (1330 N) applied at any point
to produce the maximum load effect on the element being considered. For fixed
ladders greater than 10 ft (3050 mm) in length, additional 300 lb (1330 N)
concentrated live load units are required to be applied at a minimum of one unit
for every additional 10 ft (3050 mm) of ladder length, in accordance with
ASCE/SEI 7-10. The details shown in this Practice and the fabrication details
shown in PIP STF05501 have been designed according to these live load criteria.
4.9.2 Structure/platform engineer should review ASCE/SEI 7-10 prescriptive live load
criteria and determine if it adequately addresses the intended use of the ladder. If
not, an adjusted concentrated live load unit should be determined and used to
check the ladder design.
4.9.3 Individual rungs should be designed for the concentrated live load unit
determined in Section 4.9.2 above, applied at any point along the rung.
4.9.4 Where ladder rails extend above a platform at top of the ladder, each rail
extension is required to be designed for a concentrated live load of 100 lb
(445 N) applied in any direction at any height up to top of the side rail extension,
in accordance with ASCE/SEI 7-10.
4.9.5 Fixed ladders equipped with a ladder safety system mounted directly to ladder
should be designed for an impact load determined by manufacturer of the safety
system. At a minimum, this load should be the load resulting from an 18 inch
(460 mm) drop of a 500-pound (227-kg) weight, in accordance with OSHA
Subpart D Section 1910.29(i)(6). Typically ladder safety systems manufacturers’
literature shows a range of 1300 pounds (5.8 kN) to 1500 pounds (6.7 kN).
OSHA limits the maximum arresting force on a person to 1800 pounds (8 kN).
For a ladder safety system that attaches to rungs, the impact load would typically
be distributed to several rungs or support system. Consult ladder safety system
manufacturer for load distribution. Fixed ladders shown in drawings of this
Practice have been validated for the loads above assuming that the ladder safety
system has been attached to a minimum of three rungs. It is the structure/platform
engineer’s responsibility to verify that all ladder details are adequate for the
selected ladder safety system.
4.9.6 Fixed ladders equipped with a personal fall arrest system mounted directly to the
ladder are required to be designed for the forces resulting from the 5000-pound
(22.2-kN) ultimate prescriptive anchorage force specified in OSHA 29 CFR

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1910.140(c) under Subpart I, or be designed for the anticipated load from the
system, with a minimum factor-of-safety of 2 (performance-based alternative
permitted by OSHA). Fixed ladders detailed in PIP STF05501 have not been
specifically designed for loads from an attached personal fall arrest system.
Depending on the type of personal fall arrest system selected, modification may
be required to the ladder details to accommodate the design loads of the system.
Alternatively, personal fall arrest system can be supported separately from the
ladder. It is the structure/platform engineer’s responsibility to verify that all
ladder details or alternate supports are adequate for the selected personal fall
arrest system.
4.9.7 Ladder support members and support connectors should be designed for the
following loads:
a. Dead Load = actual estimated dead load of the ladder, including cage and
ladder safety system/personal fall arrest system as applicable.
b. Live Load = total number of concentrated live load units multiplied by the
value of the unit as determined according to Sections 4.9.1 and 4.9.2 above
(e.g., Live Load = 900 lb [3990 N] for a 30 foot ladder with 3 live load units
of 300 lb [1330 N]))
c. For ladders equipped with a ladder safety system mounted directly to ladder,
an impact load equal to the load specified in Section 4.9.5 above.
d. For ladders equipped with a personal fall arrest system mounted directly to
ladder, a load determined according to Section 4.9.6 above.
4.9.8 Ladder supports and guides should be designed for ice, wind, and earthquake
loads in accordance with PIP STC01015.
4.10 Allowances for Temperature Variation for Vertical Vessels
4.10.1 For ladders at vertical vessels, the dimensions shown with an asterisk in details
on drawings PIP STE05501-01, PIP STE05501-06, and PIP STE05501-10 are
based on the vessel and ladder at ambient temperature.
4.10.2 If vertical vessel operates at a temperature above or below ambient temperature,
allowance must be made for expansion or contraction of vessel in relation to
position of ladder, since ladder will remain at ambient temperature. At base of
ladder and at ladder guide connections, this will require slots that are long
enough to accommodate the expected expansion or contraction of vessel at that
point. The required lengths of slots depends on operating temperature of vessel,
expansion coefficient of material from which vessel is fabricated, and location of
slot in relation to anchor point (support point) at top of ladder.
4.10.3 Slot lengths shown in Type 2 ladder base detail on drawing PIP STE05501-06
and guide connection detail on drawing PIP STE05501-10 allow for
approximately 3 inches (75 mm) of pin or bolt movement in slot. The engineer
should review actual design conditions to check whether this allowance is
sufficient for the particular application. Refer to Table 1 (U.S. Customary Units)
and Table 1M (Metric Units) in this Practice for thermal expansion data to assist
in determination.

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4.10.4 If 3 inches (75 mm) allowable movement is insufficient at the ladder base, it is
recommended that engineer specify Type 1 ladder base detail shown on
fabrication detail drawing PIP STF05501-06 instead of Type 2 ladder base detail.
If 3 inches (75 mm) allowable movement is insufficient at ladder guides, guide
details shown on fabrication detail drawing PIP STF05501-10 will need to be
modified with an addendum to PIP STF05501.
4.10.5 To allow for expansion of a vessel that operates at a temperature above ambient
temperature (i.e., hot vessel), position of the pins or bolts in the slots should be as
shown in the Type 2 ladder base detail on drawing PIP STE05501-06 and the guide
connection detail on drawing PIP STE05501-10.
4.10.6 To allow for contraction of a vessel that operates at a temperature below ambient
temperature (i.e., cold vessel), position of the pins or bolts in the slots shown in
the Type 2 ladder base detail on drawing PIP STE05501-06 and the guide
connection detail on drawing PIP STE05501-10 should be reversed.
4.10.7 If fabrication detail drawings included in PIP STF05501 are to be used for
vessels operating below ambient temperature, an addendum to PIP STF05501
should be prepared to reverse the position of the pins or bolts in the slots shown
in the appropriate details on fabrication detail drawings PIP STF05501-06 and
PIP STF05501-10.
4.11 Ladder Pads
4.11.1 Ladders designed in accordance with this Practice that have connections at the
base are intended to be used with ladder pad details in accordance with PIP
STI03310.
4.11.2 Ladder pads detailed in PIP STI03310 are based on a ladder pad height between
0 inch (0 mm) minimum and 1 ft (300 mm) maximum.
4.12 Ladder Clearances
4.12.1 Fixed ladders that do not have cages or wells are required to have a clear width of
15 inches (380 mm) minimum on each side of the ladder centerline to the nearest
permanent object; and a minimum perpendicular distance of 30 inches (760 mm)
from the centerline of the steps or rungs to the nearest permanent object on the
climbing side. When unavoidable obstructions are encountered, the minimum
clearance at the obstruction may be reduced to 24 inches (610 mm), provided
deflector plates are installed in accordance with OSHA requirements.
4.12.2 The minimum perpendicular distance from the centerline of rungs to the nearest
permanent object in back of the ladder is 7 inches (180 mm),

5. Ladder Fall Protection

5.1 General
With the revised OSHA regulations, the basic philosophy for ladder fall protection is to
phase out the use of cages and phase in the use of personal fall arrest or ladder safety
systems to protect employees from falls. Per OSHA, it has been clearly determined from
accident case studies that cages do not provide effective fall prevention/protection.
OSHA studies show that injuries sustained while falling through caged ladders are
typically more severe than falls from ladders without cages as body parts can be easily

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entangled in the cage during a fall. OSHA emphasizes that personal fall arrest or ladder
safety systems are inherently more effective for fall prevention/protection.
5.2 Fixed Ladders Extending more than 24 feet (7.3 m) above a Lower Level
5.2.1 According to OSHA regulations, fall protection is required for fixed ladders that
extend more than 24 ft (7.3 m) above a lower level. Sections 5.2.2 through 5.2.7
address only those ladders. Fixed ladders can extend up to 24 ft (7.3 m) above a
lower level without having any type of fall protection, cage or well. It is
important to note that the definition of “lower level” is the level to which an
employee could fall. This may be different than the level of the ladder base. See
Appendix A for guidance on interpretation of the OSHA regulations relevant to
this subject.
5.2.2 OSHA regulations provide for a gradual phase-in of ladder safety
systems/personal fall arrest systems and phase-out of cages or wells over a
20-year extended compliance period. This 20-year period starts from the
publication date of the revised OSHA regulations on November 18, 2016 and
extends until November 18, 2036.
5.2.3 For existing fixed ladders (i.e., installed before November 19, 2018), employers
have until November 18, 2036 to install personal fall arrest or ladder safety
systems. During the 20-year extended compliance period, existing ladders must
have personal fall arrest systems, ladder safety systems, cages or wells. This
means that existing fixed ladders may continue to be used during the 20-year
extended compliance period, even if they are equipped only with cages or wells.
5.2.4 New fixed ladders (i.e., installed on or after November 19, 2018) must be equipped
with a personal fall arrest system or ladder safety system at time of installation.
Note that, by OSHA definition, cages and wells are not ladder safety systems.
5.2.5 When a fixed ladder, cage or well, or any part thereof, is replaced, a personal fall
arrest or ladder safety system must be installed on at least that section of the
fixed ladder where the replacement is located.
5.2.6 By the end of the 20-year extended compliance period, all fixed ladders must be
equipped with either personal fall arrest systems or ladder safety systems.
Ladders may still be equipped with cages or wells, but these will not be
considered a means of fall protection.
5.2.7 The fixed ladder fabrication details shown in PIP STF05501 for new ladders
have been developed to allow for the installation of a ladder safety system (See
Section 4.9.5). A personal fall arrest system may require support independent
from the ladder. PIP ladder details are not specifically designed for attached
personal fall arrest systems (See Section 4.9.6).
5.3 Considerations for Compliance with OSHA Fall Protection Regulations for
Fixed Ladders
5.3.1 For fixed ladders that require fall protection, consultation between owner’s safety
representative, facility operations and maintenance personnel, project
engineering and management teams is necessary to determine the best options to
meet OSHA regulations for specific applications.

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5.3.2 The owner will need to decide where personal fall protection and/or ladder safety
systems are required and which type to use. For each system, there are several
types available. Ladder safety systems can be a rigid carrier type where the worker
clips into a rail mounted on the ladder or a flexible carrier type where the worker
attaches to a cable running up the ladder. Personal fall arrest systems can be an
independent system supported from structure above the ladder or a davit type
which mounts directly to the top of the ladder. Each option will require changes in
facility protocols, training and Personal Protective Equipment (PPE) requirements.
5.3.3 Owners will need to establish appropriate safety protocols for using fixed ladders
that have ladder safety systems or personal fall arrest systems. Ladder safety
systems must include the ability to safely connect to and disconnect from the
system at the top of the ladder. This requirement may require the installation and
use of a separate personal fall arrest system at the top of each ladder equipped
with a ladder safety system. If this step is necessary, it may be a better option to
simply use the personal fall arrest system to provide the required fall protection
for the ladder.
5.3.4 Owners will also need to develop specific strategies for meeting fall protection
regulations for retrofitting existing fixed ladders to achieve compliance and
consistency over the long term for safe, practical, functional and cost-effective
use of all ladders in their facilities.
5.3.5 Owners may wish to avoid having to install personal fall arrest or ladder safety
systems on any fixed ladders, because of concerns about maintenance, training
and PPE requirements. With current OSHA regulations, the only way to do this
is to limit the length of all ladders to 24 ft (7.3 m) above a lower level. This may
be impractical in some applications, or it may require adding additional platform
levels which are otherwise unnecessary for operations. Also, a ladder whose base
is near the edge of an elevated platform will require fall protection if the potential
fall height to a lower level below the elevated platform exceeds 24 ft (7.3 m),
even if the climbing length of the ladder is less than 24 ft (7.3 m). For further
discussion on this subject, refer to Appendix A of this Practice.
5.3.6 One significant concern with implementation of alternate compliance approaches
(e.g., longer ladders with ladder safety systems with or without cages) is
employee safety during an emergency evacuation situation. Many ladders in PIP
member facilities are placed specifically for emergency evacuation purposes,
during which employee use of a ladder safety system may be unlikely or even ill-
advised. Longer ladders – even with cages – would result in a longer potential
fall; use of a ladder safety system would result in delayed evacuation and greater
exposure to the hazard (fire, toxic gas, etc.). The use of stairs is the best means
of emergency egress and providing stairs rather than ladders in some
circumstances should be considered. See also Section 4.4.2 for a discussion of
the use cages in conjunction with ladders that have personal fall arrest or ladder
safety systems.
5.3.7 When a ladder safety system or personal fall arrest system is used, consider
establishing a single type of system for the facility to simplify maintenance
issues, training, and harness hook-up requirements throughout the facility.

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5.3.8 Consider signage for ladders with personal fall arrest or ladder safety systems,
informing employees that training and harness hook-up are required to climb the
ladder.
5.4 Ladder Safety System Requirements
5.4.1 Ladder safety system must allow employee to climb up and down without
employee continuously holding, pushing or pulling any part of the system.
5.4.2 Connection between carrier and point of attachment to the body harness must not
be greater than 9 inches (230 mm).
5.4.3 Mountings for rigid carriers must be attached at each end of the carrier, with
intermediate mountings spaced, as necessary, along the entire length of carrier so
the system has the strength to stop employee falls.
5.4.4 Mountings for flexible carriers must be attached at each end of carrier and cable
guides must be installed at least 25 feet (7.6 m) apart but not more than 40 feet
(12.2 m) apart along entire length of the carrier.
5.4.5 Design and installation of mountings and cable guides must not reduce design
strength of the ladder.
5.4.6 Distance of the flare of the ladder rails at step through ladders may be increased
to 36 inch (910 mm) maximum to accommodate access through the ladder rails
where a ladder safety system is used.
5.5 Personal Fall Arrest System Requirements
All components of personal fall arrest systems (anchorage, connecting devices, body
harnesses, etc.) must meet the requirements of the OSHA regulations for personal fall
protection systems found in 29 CFR Part 1910 Subpart I, Section 1910.140.

6. Inspection, Tagging, Use and Training Requirements

6.1 OSHA provides ladder and personal fall protection systems inspection, tagging, use and
training requirements that affect safety and PPE protocols within a facility.
6.2 Ladder inspection and tagging requirements are addressed in OSHA 29 CFR Part 1910
Subpart D, Sections 1910.23(b)(9) and (10).
6.3 Proper use of ladders by employees is addressed in OSHA 29 CFR Part 1910 Subpart D,
Sections 1910.23(b)(11) through (13).
6.4 Training requirements related to fall hazards and procedures for minimizing those
hazards with the proper use of personal fall protection systems are addressed in OSHA 29
CFR Part 1910 Subpart D, Sections 1910.30(a), (c), and (d).
6.5 Requirements for personal fall protection systems are comprehensively addressed in
OSHA 29 CFR Part 1910 Subpart I, Section 1910.140.

7. Contract Documents
7.1 The following information should be shown in design documents or other contract
documents by structure/platform engineer and/or vessel engineer as applicable:

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a. Location and orientation of ladder and optional cage including centerline of rungs in
the plane of the ladder and centerline of ladder perpendicular to plane of ladder
b. Location of safety gate hinges relative to orientation of ladder
c. Safety gate specifications, including approved manufacturer(s) and model number(s)
(safety gates to be supplied by guard fabricator)
d. Selection of Type 1 ladder base (preferred – no connection at base) or Type 2 ladder
base (with connection at base) for ladders at vertical vessels. See ladder base details
on drawing PIP STE05501-06.
e. Top of bottom rung elevation for ladders at vertical vessels with Type 1 ladder base.
See ladder base details on drawing PIP STE05501-06.
f. Bottom of ladder elevation for ladders at structures/platforms and horizontal vessels,
and ladders at vertical vessels with Type 2 ladder base. See ladder base details on
drawings PIP STE05501-05 and PIP STE05501-06.
g. Top of platform elevations (walking surface) for platforms serviced by ladder
h. Locations and details for ladder support members and support connectors to
structures/platforms or vessels
i. Locations and details for ladder guide connectors to structures/platforms or vessels
j. Whether a cage is to be provided for ladder
k. Whether extended vertical bars are required for cage at an elevated platform
l. Bottom of cage elevation if a cage is used
m. Width of flare at top of rails for through ladders
n. Locations of gaps between ladder segments (for continuous ladders with multiple
segments)
o. Ladder safety system and/or personal fall arrest system specifications, including
approved manufacturer(s) and model number(s) (ladder safety systems and/or personal
fall arrest systems to be supplied by ladder fabricator or by separate PO with supplier)
7.2 The following information should be included in an addendum to PIP STF05501 or
specified elsewhere in the contract documents if applicable:
a. Alternate slotted ladder base and guide connection details for ladders on vertical
vessels
b. Design loads for support members, support connectors, and guide connectors to
structures/platforms if connection design is in the scope of services provided by
structure/platform fabricator
c. Ladder rail selection criteria if different than specified in PIP STF05501
d. Rung length, diameter, and associated details, such as requirements for slip-resistant
rungs, if different than 1 ft-6 inches (460 mm) long 3/4 inch (20 mm) diameter
smooth bar
e. Ladder rung spacing if different than 1 ft-0 inch (300 mm)
f. Details for ladders with a pitch less than 90 degrees from horizontal

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g. Structural steel material if different than specified in PIP STF05501

h. Metric equivalents for plates, bars, and structural shapes
i. Alternative or additional coatings for ladder assemblies (e.g., safety yellow paint) if
different from requirements specified in PIP STF05501
j. Minimum required swing angle of safety gates if greater than 90 degrees
k. Any other requirements that are different or in addition to PIP STF05501

8. Fabricator Shop Drawings Review

Fabricator shop drawings should be reviewed by structure/platform engineer and/or vessel
engineer as applicable to ensure drawings are in accordance with PIP STS05120, PIP STF05501,
relevant design documents, and other contract documents as applicable. Drawing reviews should
include the following checks:

a. Latest revisions of structure/platform and/or vessel design documents, and ladder design
documents have been used as applicable
b. Fabricator shop drawings are in accordance with material specifications, dimensions,
fabrication details, and other requirements as specified in PIP STS05120 and PIP STF05501
c. Ladder orientations and locations are correct
d. Top of bottom rung elevations for ladders at vertical vessels with Type 1 ladder base (no
connection at base) are correct and ladder base is detailed in accordance with fabrication
detail drawing PIP STF05501-06
e. Bottom of ladder elevations for ladders at structures/platforms and horizontal vessels, and
ladders at vertical vessels with Type 2 ladder base (with connection at base) are correct and
ladder base is detailed in accordance with fabrication detail drawings PIP STF05501-05 and
PIP STF05501-06
f. Top of platform elevations are correct and even with top of ladder rungs at platforms
g. Ladder rail sizes are selected correctly in accordance with guide locations shown in design
documents and unguided length criteria shown on fabrication detail drawing
PIP STF05501-01
h. Plates connecting ladders to support connectors on structures/platforms and/or vessels at top
of ladders are located and detailed correctly in accordance with design documents and
fabrication detail drawings PIP STF05501-07 through PIP STF05501-09
i. Slotted plates connecting ladders to guide connectors on structures/platforms and/or vessels
are located and detailed correctly in accordance with design documents and fabrication
detail drawings PIP STF05501-10 and PIP STF05501-11
j. Support members, support connectors, and guide connectors to structures/platforms and/or
vessels are located and detailed correctly in accordance with design documents
k. Support members, support connectors, and guide connectors to structures/platforms are
designed correctly by structure/platform fabricator if connection design is in the scope of
services provided by structure/platform fabricator
l. Cages are provided where specified

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m. Bottom of cage elevations are correct

n. Vertical bars of cages are extended to top rail of railing on the platform if required for
ladders at elevated platforms
o. Width of flare at top of the rails for through ladders is correct
p. Locations of centerlines of gap between ladder segments (for continuous ladders with
multiple segments) are correct
q. Galvanizing requirements are shown correctly
r. Additional coating requirements, if required, are shown correctly
s. Sufficient quantities of specified bolts required for erection of ladder assemblies are
indicated to be provided by ladder fabricator

9. Typical Details
Typical details for design of fixed ladders are shown in drawings appended to this Practice (i.e.,
Drawings PIP STE05501-01 through PIP STE05501-18). Some of the typical details show angle
guards in relation to ladder details but pipe guards are equally applicable. See PIP STF05501 for
specific fabrication details for fixed ladders with angle guards and pipe guards.

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Table 1 - Thermal Expansion Data (U.S. Customary Units)

Total linear expansion between 70°F and indicated temperature (inches/100 ft)

Temp. Temp.
Vessel Material
(°F) (°F)
Carbon Steel 5 Cr Mo Austenitic 12 Cr 12 Cr Monel 3-1/2 Ni-Fe-Cr
Carbon - Moly through Stainless 17 Cr 20 Ni 67 Ni Nickel
Low-Chrome 9 Cr Mo Steels 27 Cr 30 Cu
(through 18 Cr 8 Ni
3 Cr Mo)
70 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 70
100 0.23 0.22 0.34 0.20 0.32 0.28 0.23 0.28 100
125 0.42 0.40 0.62 0.36 0.58 0.52 0.42 0.52 125
150 0.61 0.58 0.90 0.53 0.84 0.75 0.61 0.76 150
175 0.80 0.76 1.18 0.69 1.10 0.99 0.81 0.99 175
200 0.99 0.94 1.46 0.86 1.37 1.22 1.01 1.23 200
225 1.21 1.13 1.75 1.03 1.64 1.46 1.21 1.49 225
250 1.40 1.33 2.03 1.21 1.91 1.71 1.42 1.76 250
275 1.61 1.52 2.32 1.38 2.18 1.96 1.63 2.03 275
300 1.82 1.71 2.61 1.56 2.45 2.21 1.84 2.30 300
325 2.04 1.90 2.90 1.74 2.72 2.44 2.05 2.59 325
350 2.26 2.10 3.20 1.93 2.99 2.68 2.26 2.88 350
375 2.48 2.30 3.50 2.11 3.26 2.91 2.47 3.18 375
400 2.70 2.50 3.80 2.30 3.53 3.25 2.69 3.48 400
425 2.93 2.72 4.10 2.50 3.80 3.52 2.91 3.76 425
450 3.16 2.93 4.41 2.69 4.07 3.79 3.13 4.04 450
475 3.39 3.14 4.71 2.89 4.34 4.06 3.35 4.31 475
500 3.62 3.35 5.01 3.08 4.61 4.33 3.58 4.59 500
525 3.86 3.58 5.31 3.28 4.88 4.61 3.81 4.87 525
550 4.11 3.80 5.62 3.49 5.15 4.90 4.04 5.16 550
575 4.35 4.02 5.93 3.69 5.42 5.18 4.27 5.44 575
600 4.60 4.24 6.24 3.90 5.69 5.46 4.50 5.72 600
625 4.86 4.47 6.55 4.10 5.96 5.75 4.74 6.01 625
650 5.11 4.69 6.87 4.31 6.23 6.05 4.98 6.30 650
675 5.37 4.92 7.18 4.52 6.50 6.34 5.22 6.58 675
700 5.63 5.14 7.50 4.73 6.77 6.64 5.46 6.88 700
725 5.90 5.38 7.82 4.94 7.04 6.94 5.70 7.17 725
750 6.16 5.62 8.15 5.16 7.31 7.25 5.94 7.47 750
775 6.43 5.86 8.47 5.38 7.58 7.55 6.18 7.76 775
800 6.70 6.10 8.80 5.60 7.85 7.85 6.43 8.06 800
825 6.97 6.34 9.13 5.82 8.15 8.16 6.68 8.35 825
850 7.25 6.59 9.46 6.05 8.45 8.48 6.93 8.66 850
875 7.53 6.83 9.79 6.27 8.75 8.80 7.18 8.95 875
900 7.81 7.07 10.12 6.49 9.05 9.12 7.43 9.26 900
925 8.08 7.31 10.46 6.71 9.35 9.44 7.68 9.56 925
950 8.35 7.56 10.80 6.94 9.65 9.77 7.93 9.87 950
975 8.62 7.81 11.14 7.17 9.95 10.09 8.17 10.18 975
1000 8.89 8.06 11.48 7.40 10.25 10.42 8.41 10.49 1000
1025 9.17 8.30 11.82 7.62 10.55 10.75 10.80 1025
1050 9.46 8.55 12.16 7.95 10.85 11.09 11.11 1050
1075 9.75 8.80 12.50 8.18 11.15 11.43 11.42 1075
1100 10.04 9.05 12.84 8.31 11.45 11.77 11.74 1100

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Table 1 (continued)

Total linear expansion between 70°F and indicated temperature (inches/100 ft)

Temp. Temp.
Vessel Material
(°F) (°F)
Carbon Steel 5 Cr Mo Austenitic 12 Cr 12 Cr Monel 3-1/2 Ni-Fe-Cr
Carbon - Moly through Stainless 17 Cr 20 Ni 67 Ni Nickel
Low-Chrome 9 Cr Mo Steels 27 Cr 30 Cu
(through 18 Cr 8 Ni
3 Cr Mo)
1125 10.31 9.28 13.18 8.53 11.78 12.11 12.05 1125
1150 10.57 9.52 13.52 8.76 12.11 12.47 12.38 1150
1175 10.83 9.76 13.86 8.98 12.44 12.81 12.69 1175
1200 11.10 10.00 14.20 9.20 12.77 13.15 13.02 1200
1225 11.38 10.26 14.54 9.42 13.10 13.50 13.36 1225
1250 11.66 10.53 14.88 9.65 13.43 13.86 13.71 1250
1275 11.94 10.79 15.22 9.88 13.76 14.22 14.04 1275
1300 12.22 11.06 15.56 10.11 14.09 14.58 14.39 1300
1325 12.50 11.30 15.90 10.33 14.39 14.94 14.74 1325
1350 12.78 11.55 16.24 10.56 14.69 15.30 15.10 1350
1375 13.06 11.80 16.58 10.78 14.99 15.66 15.44 1375
1400 13.34 12.05 16.92 11.01 15.29 16.02 15.80 1400
1425 17.30 16.16 1425
1450 17.69 16.53 1450
1475 18.08 16.88 1475
1500 18.47 17.25 1500

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Table 1M - Thermal Expansion Data (Metric Units)

Total linear expansion between 21°C and indicated temperature (mm/m)

Temp. Temp.
Vessel Material
(°C) (°C)
Carbon Steel 5 Cr Mo Austenitic 12 Cr 12 Cr Monel 3-1/2 Ni-Fe-
Carbon - Moly through Stainless 17 Cr 20 Ni 67 Ni Nickel Cr
Low-Chrome 9 Cr Mo Steels 27 Cr 30 Cu
(through 18 Cr 8 Ni
3 Cr Mo)
21 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 21
38 0.19 0.18 0.28 0.17 0.27 0.23 0.19 0.23 38
52 0.35 0.33 0.52 0.30 0.48 0.43 0.35 0.43 52
66 0.51 0.48 0.75 0.44 0.70 0.63 0.51 0.63 66
79 0.67 0.63 0.98 0.58 0.92 0.83 0.68 0.83 79
93 0.83 0.78 1.22 0.72 1.14 1.02 0.84 1.03 93
107 1.01 0.94 1.46 0.86 1.37 1.22 1.01 1.24 107
121 1.17 1.11 1.69 1.01 1.59 1.43 1.18 1.47 121
135 1.34 1.27 1.93 1.15 1.82 1.63 1.36 1.69 135
149 1.52 1.43 2.18 1.30 2.04 1.84 1.53 1.92 149
163 1.70 1.58 2.42 1.45 2.27 2.03 1.71 2.16 163
177 1.88 1.75 2.67 1.61 2.49 2.23 1.88 2.40 177
191 2.07 1.92 2.92 1.76 2.72 2.43 2.06 2.65 191
204 2.25 2.08 3.17 1.92 2.94 2.71 2.24 2.90 204
218 2.44 2.27 3.42 2.08 3.17 2.93 2.43 3.13 218
232 2.63 2.44 3.68 2.24 3.39 3.16 2.61 3.37 232
246 2.83 2.62 3.93 2.41 3.62 3.38 2.79 3.59 246
260 3.02 2.79 4.18 2.57 3.84 3.61 2.98 3.83 260
274 3.22 2.98 4.43 2.73 4.07 3.84 3.18 4.06 274
288 3.43 3.17 4.68 2.91 4.29 4.08 3.37 4.30 288
302 3.63 3.35 4.94 3.08 4.52 4.32 3.56 4.53 302
316 3.83 3.53 5.20 3.25 4.74 4.55 3.75 4.77 316
329 4.05 3.73 5.46 3.42 4.97 4.79 3.95 5.01 329
343 4.26 3.91 5.73 3.59 5.19 5.04 4.15 5.25 343
357 4.48 4.10 5.98 3.77 5.42 5.28 4.35 5.48 357
371 4.69 4.28 6.25 3.94 5.64 5.53 4.55 5.73 371
385 4.92 4.48 6.52 4.12 5.87 5.78 4.75 5.98 385
399 5.13 4.68 6.79 4.30 6.09 6.04 4.95 6.23 399
413 5.36 4.88 7.06 4.48 6.32 6.29 5.15 6.47 413
427 5.58 5.08 7.33 4.67 6.54 6.54 5.36 6.72 427
441 5.81 5.28 7.61 4.85 6.79 6.80 5.57 6.96 441
454 6.04 5.49 7.88 5.04 7.04 7.07 5.78 7.22 454
468 6.28 5.69 8.16 5.23 7.29 7.33 5.98 7.46 468
482 6.51 5.89 8.43 5.41 7.54 7.60 6.19 7.72 482
496 6.73 6.09 8.72 5.59 7.79 7.87 6.40 7.97 496
510 6.96 6.30 9.00 5.78 8.04 8.14 6.61 8.23 510
524 7.18 6.51 9.28 5.98 8.29 8.41 6.81 8.48 524
538 7.41 6.72 9.57 6.17 8.54 8.68 7.01 8.74 538
552 7.64 6.92 9.85 6.35 8.79 8.96 9.00 552
566 7.88 7.13 10.13 6.63 9.04 9.24 9.26 566
579 8.13 7.33 10.42 6.82 9.29 9.53 9.52 579
593 8.37 7.54 10.70 6.93 9.54 9.81 9.78 593

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Table 1M (continued)

Total linear expansion between 21°C and indicated temperature (mm/m)

Temp. Temp.
Vessel Material
(°C) (°C)
Carbon Steel 5 Cr Mo Austenitic 12 Cr 12 Cr Monel 3-1/2 Ni-Fe-Cr
Carbon - Moly through Stainless 17 Cr 20 Ni 67 Ni Nickel
Low-Chrome 9 Cr Mo Steels 27 Cr 30 Cu
(through 18 Cr 8 Ni
3 Cr Mo)
607 8.59 7.73 10.98 7.11 9.82 10.09 10.04 607
621 8.81 7.93 11.27 7.30 10.09 10.39 10.32 621
635 9.03 8.13 11.55 7.48 10.37 10.68 10.58 635
649 9.25 8.33 11.83 7.67 10.64 10.96 10.85 649
663 9.48 8.55 12.12 7.85 10.92 11.25 11.13 663
677 9.72 8.78 12.40 8.04 11.19 11.55 11.43 677
691 9.95 8.99 12.68 8.23 11.47 11.85 11.70 691
704 10.18 9.22 12.97 8.43 11.74 12.15 11.99 704
718 10.42 9.42 13.25 8.61 11.99 12.45 12.28 718
732 10.65 9.63 13.53 8.80 12.24 12.75 12.58 732
746 10.88 9.83 13.82 8.98 12.49 13.05 12.87 746
760 11.12 10.04 14.10 9.18 12.74 13.35 13.17 760
774 14.42 13.47 774
788 14.74 13.78 788
802 15.07 14.07 802
816 15.39 14.38 816

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APPENDIX A - Commentary on Interpretation of OSHA Regulations 29 CFR Part

1910 Subpart D, Section 1910.28(b)(9)
On November 18, 2016, OSHA published in the Federal Register Volume 81, No. 223, new and revised
general industry standards on walking-working surfaces and personal protective equipment. These
updates to 29 CFR Part 1910 Subparts D and I are referred to by OSHA as the “final rule.”

Paragraph 1910.28(b)(9) of the final rule requires employers to provide fall protection for fixed ladders
that extend more than 24 feet (7.3 m) above a lower level. It is very important to understand that OSHA
bases the fall protection requirements for a fixed ladder on the height that the ladder extends above a
lower level and not the climb length of the ladder. In section 1910.21(b) of the final rule, the term “lower
level” is defined by OSHA as follows:

“Lower level means a surface or area to which an employee could fall. Such surfaces or areas include,
but are not limited to, ground levels, floors, roofs, ramps, runways, excavations, pits, tanks, materials,
water, equipment, and similar surfaces and structures, or portions thereof.”

Based on this definition, the lower level associated with a fixed ladder is not necessarily the base of the
ladder. It is the level to which an employee could fall.

Paragraph 1910.28(b)(9)(i)(A) of the final rule provides fixed ladder fall protection requirements for
existing fixed ladders (defined as fixed ladders installed before November 19, 2018), and paragraph
1910.28(b)(9)(i)(B) of the final rule provides fall protection requirements for new fixed ladders (i.e. fixed
ladders installed on or after November 19, 2018). Appendix A addresses an interpretation issue
concerning the requirements for new fixed ladders according to 1910.28(b)(9)(i)(B).

Issue regarding how to interpret final paragraph 1910.28(b)(9)(i)(B) for certain ladders

Paragraph 1910.28(b)(9)(i)(B) of the final rule requires a ladder more than 24 feet (7.3 m) above a lower
level to be equipped with a ladder safety or personal fall arrest system, but a question arises about how to
interpret this rule for a new fixed ladder with a climb length of 24 feet (7.3 m) or less where the top of the
ladder is more than 24 feet (7.3 m) above grade. What is required if an employer installs on this ladder a
cage that is designed to direct a falling employee to the base of the ladder? Does adding a cage change
the lower level associated with the ladder (i.e. the “surface or area to which an employee could fall”) such
that it is now the base of the ladder, thereby eliminating the need for fall protection on this ladder? Is this
an acceptable interpretation of the requirements of the final rule?

The argument for this interpretation

OSHA states in the preamble to the final rule that one of the objectives of the final rule is to give
employers greater flexibility in complying with the regulations. One of the options when a workplace
hazard exists is to use engineering controls to eliminate the hazard. By installing a cage on the ladder in
the situation discussed above and designing it to contain a falling employee and direct the employee’s fall
to the base of the ladder, the employee can no longer fall to a level below the base of the ladder. Thus, by
using engineering, the employer has changed the lower level to which an employee could fall in this
situation; it becomes the bottom of the ladder. Because the climb length of the ladder is not greater than
24 feet (7.3 m), the ladder no longer extends more than 24 feet (7.3 m) above a lower level. Thus, the
ladder is outside the scope of paragraph 1910.28(b)(9) of the final rule, which according to its title applies

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only to ladders that extend more than 24 feet (7.3 m) above a lower level. Therefore, the entire paragraph
1910.28(b)(9) of the final rule, and all of the discussion in the preamble regarding this paragraph, does not
apply to this ladder.

The effectiveness of cages at altering the potential landing of a fall is confirmed by language in the
preamble to the final rule, which was published along with the final rule in the Federal Register, Vol. 81,
No. 223, on November 18, 2016. On page 82521 of that publication, the preamble states that cages (and
also wells) contain employees within the enclosure and direct their fall to a lower landing.

The argument against this interpretation

The argument against this interpretation relies on language found in the preamble to the final rule, which
was published along with the final rule in the Federal Register, Vol. 81, No. 223, on November 18, 2016.
On page 82604 of that publication, the preamble provides statements which make it clear that, even
though cages and wells are not prohibited to be used in addition to ladder safety or personal fall arrest
systems, they may not be used instead of providing ladder safety and personal fall arrest systems when
they are required. The preamble cites two examples from ANSI/ASC A14.3-2008 that describe exactly the
situation under discussion here. The first is for a one-section ladder and the second is for a multiple-
section ladder. As stated in the preamble, ANSI/ASC A14.3-2008 allows the installation of ladders with
only cages in those situations, but paragraph 1910.28(b)(9)(i)(B) of the final rule is “unlike ANSI/ASC
A14.3-2008” in those situations. Also as stated in the preamble OSHA did not adopt the approach of
ANSI/ASC A14.3-2008 because evidence shows that cages and wells do not prevent employees from
falling off ladders or protect employees from injury if they fall. According to the preamble, OSHA
believes the final rule is more protective to employees than ANSI/ASC A14.3-2008.

With the above language in the preamble, OSHA makes it clear that, regarding the situation under
discussion here, the approach taken by ANSI/ASC A14.3-2008 (installing ladders with only cages) is not
adopted by OSHA in paragraph1910.28(b)(9)(i)(B) of the final rule. Thus, the idea that a cage can be
added to a fixed ladder to eliminate the requirement to provide fall protection for that ladder is not in
agreement with what OSHA intended to accomplish with the final rule.

Conclusions

As can be seen from the above discussion, there are compelling arguments on both sides of this issue. PIP
has sent a letter to OSHA requesting an interpretation of paragraph 1910.28(b)(9) of the final rule as it
applies to the situation under discussion. Up to the publication date of this Practice, OSHA has not yet
responded to this request. Each PIP Member Company will need to make their own decision on how they
will interpret the regulations to address this particular situation. The decision should consider employee
safety, facility operations and safety protocols, and the potential risks and liabilities related to their
interpretation.

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