Ladder Safety in Doorways: A Regulatory Gap That Needs to Be Closed

A Tragic Example: When a Ladder Becomes a Deadly Obstacle

In 2016, a construction worker in New York was working on an extension ladder placed in front of an active doorway. A colleague unknowingly opened the door, knocking the ladder over and sending the worker tumbling 15 feet to the ground. The worker suffered fatal head injuries from the fall. This tragedy could have been prevented with proper ladder placement and regulatory enforcement.

OSHA’s construction standard 29 CFR 1926.1053(b)(8) specifically addresses this type of hazard, stating:

“Ladders shall not be placed in passageways, doorways, driveways, or any location where they may be displaced by other activities or traffic unless secured to prevent displacement or a barricade is provided to keep traffic or activity away from the ladder.”

This clear rule exists in construction to prevent incidents like this. However, general industry lacks an equivalent regulation, leaving workers vulnerable to the same type of preventable accident.

Why This Hazard Is Overlooked: Inattention Blindness

One reason workers may not recognize this hazard is inattention blindness—a psychological phenomenon where individuals fail to see something in plain sight because their attention is focused elsewhere.

For example:

• A worker opening a door may be focused on carrying materials, not expecting a ladder to be in their path.

• A ladder user may assume that others will see and avoid the ladder, even if it is not properly secured.

• Safety managers may overlook the hazard in general industry because no specific OSHA standard explicitly prohibits ladder placement in front of doors.

Because of this gap in awareness and regulations, many workplaces unknowingly expose workers to unnecessary risks.

The General Industry Gap: Why This Hazard Still Gets Cited

Unlike in construction, general industry (29 CFR 1910.23) does not have a regulation specifically preventing ladder placement in doorways. However, OSHA can still cite this hazard under other standards, such as:

• The General Duty Clause (OSH Act, Section 5(a)(1))

  • Employers are responsible for providing a workplace free of recognized hazards that could cause serious injury or death.

  • If OSHA can prove that placing a ladder in front of a door is a known hazard, they can issue a General Duty Clause citation.

• 1910.176(a) – Handling Materials and Housekeeping

  • Requires that passageways and aisles be kept clear and free of obstructions.

  • A ladder in front of a door could be considered an obstruction, leading to a citation.

• 1910.22(a)(1) – Housekeeping

  • Requires that workplaces be kept orderly and safe.

  • An unsecured ladder in front of a doorway could be classified as unsafe conditions under this rule.

While these standards allow OSHA to address the issue in some cases, they do not explicitly prohibit ladder placement in front of doors like the construction standard does.

Why OSHA Should Close This Gap

The lack of a clear, enforceable regulation in general industry creates inconsistent safety enforcement and leaves workers at risk. Here’s why OSHA should add a regulation similar to 1926.1053(b)(8) to the general industry standards:

1. Prevention of Fatalities and Injuries

   • Falls from ladders remain a leading cause of workplace fatalities. A simple rule like this could prevent accidents and save lives.

2. Consistency Across Industries

   • The hazard is the same in both construction and general industry. It makes no sense for one sector to be protected while the other is not.

3. Eliminating Enforcement Gaps

   • Relying on general housekeeping rules or the General Duty Clause makes enforcement inconsistent. A clear standard would make compliance easier for employers and enforcement more effective for OSHA.

4. Increased Awareness of the Hazard

   • Many workplaces don’t realize this is a problem until an incident happens. A dedicated regulation would help raise awareness and improve training on ladder placement safety.

Conclusion

A small regulatory gap is putting general industry workers at unnecessary risk. While OSHA can still cite unsafe ladder placement through other standards, there is no direct equivalent to 1926.1053(b)(8) in general industry. A simple regulatory change could prevent future fatalities.

It’s time for OSHA to close this gap and extend clear protections to all workers—no matter the industry.