OSHA’s ship ladder requirements sit in 29 CFR 1915.72, part of Subpart E of the shipyard employment standards, and they apply to ship repairing, shipbuilding, and shipbreaking. The rule focuses almost entirely on portable ladders: how they must be secured, how far they must extend above a landing, how wood ladders must be built, and when a defective ladder has to come out of service. Related sections cover access to vessels (1915.74) and to dry docks (1915.75). Violations carry OSHA’s standard penalties, up to $16,550 for a serious citation and $165,514 for willful or repeated ones.
Portable Ladder Rules Under 1915.72
Every portable ladder used in a shipyard must be lashed, blocked, or otherwise secured so it cannot shift or slip during use.1Occupational Safety and Health Administration. 29 CFR 1915.72 – Ladders Securing is the requirement an inspector will check first, and it is not optional based on how briefly the ladder is in place.
When a portable ladder gives access to an upper level, the side rails must extend at least 36 inches above the landing surface. Where extending the rails is not practical, grab rails providing a secure handhold must be installed at the access point instead.1Occupational Safety and Health Administration. 29 CFR 1915.72 – Ladders
Construction Specs for Wood Ladders
Manufactured portable wood ladders must comply with ANSI Standard A14.1-1975. Site-built ladders have to be made from West Coast hemlock, Eastern spruce, Sitka spruce, or wood of equivalent strength. Low-density woods are prohibited.1Occupational Safety and Health Administration. 29 CFR 1915.72 – Ladders
The wood itself must be seasoned, straight-grained, and free of shakes, checks, decay, or other strength-reducing defects. Side rails must be dressed on all sides and kept free of splinters. Knots are allowed only if sound and hard. They cannot exceed half an inch in diameter on the side face of a rail, cannot appear within half an inch of a rail edge, and cannot sit closer than three inches to a rung. Knots on the narrow face of the rail are not permitted at all.1Occupational Safety and Health Administration. 29 CFR 1915.72 – Ladders
Dimensions depend on length. For ladders up to 30 feet, side rails must measure at least 1⅝ by 3⅝ inches in cross section. The width between rails at the base must be at least 11½ inches for ladders 10 feet or shorter, with an extra quarter inch of width for each additional two feet of length. Cleats must be uniformly spaced no more than 12 inches apart, made from the same species as the side rails, and fastened to each rail with at least three 10d common wire nails or equivalent.1Occupational Safety and Health Administration. 29 CFR 1915.72 – Ladders
Ladders between 30 and 60 feet follow the same general rules but require heavier lumber: rails of at least 2 by 6 inches and cleats of at least 1 by 4 inches, each secured with five 10d nails or equivalent.1Occupational Safety and Health Administration. 29 CFR 1915.72 – Ladders
Defective Ladders and Inspection
Ladders with broken or missing rungs, cracked side rails, or any other structural defect cannot be used. When a defect is discovered, the ladder must come out of service immediately, not be set aside for later repair.1Occupational Safety and Health Administration. 29 CFR 1915.72 – Ladders The regulation does not describe a formal tagging procedure, but the withdrawal must happen the moment the defect is found.
Inspection of metal ladders has to include checking for corrosion inside open-ended hollow rungs.1Occupational Safety and Health Administration. 29 CFR 1915.72 – Ladders That is the failure point invisible from the outside, and the one that causes rungs to give way with no warning.
When a Metal Ladder Is Off-Limits
Portable metal ladders may not be used near electrical conductors or during electric arc welding operations.1Occupational Safety and Health Administration. 29 CFR 1915.72 – Ladders If the task involves either, use a non-conductive ladder.
Getting On and Off the Vessel
Access to a vessel afloat is regulated separately, at 29 CFR 1915.74, and it sets a clear hierarchy. The preferred method is a gangway at least 20 inches wide, of adequate strength, safely secured, and maintained in good repair. Each side of the gangway and any turntable must have a railing at least 33 inches high, measured from the walking surface at the stanchion, with a midrail. The rails can be wood, pipe, chain, wire, or rope, and they must be kept taut.2Occupational Safety and Health Administration. 29 CFR 1915.74 – Access to Vessels
If a gangway is not practical, a straight ladder is next. It must extend at least 36 inches above the upper landing surface and be secured against shifting or slipping. A Jacob’s ladder is the last resort. It has to be the double-rung or flat-tread type, well maintained, and properly secured, hanging taut or pulled up entirely, with no loose slack.2Occupational Safety and Health Administration. 29 CFR 1915.74 – Access to Vessels
Nothing may be placed on or across the gangway, and the full length of the access path must be adequately illuminated. If the foot of the gangway ends more than one foot from the apron edge, the gap must be bridged by a firm walkway with 33-inch railings and midrails on both sides.2Occupational Safety and Health Administration. 29 CFR 1915.74 – Access to Vessels When two or more vessels, other than barges or river towboats, are moored side by side, the same gangway requirements apply between them.3eCFR. 29 CFR 1915.74 – Access to Vessels
Dry Dock Access Railings
Dry dock access lives under 29 CFR 1915.75, and the railing heights are not the same as vessel access. A gangway, ramp, or permanent stairway at least 20 inches wide must connect a floating dry dock to the pier or bulkhead. Gangways and ramps require railings approximately 42 inches high with a midrail on each side. Permanent stairways need railings between approximately 30 and 34 inches. The same railing rules apply to access from dry dock floors to wing walls.4Occupational Safety and Health Administration. 29 CFR 1915.75 – Access to and Guarding of Dry Docks and Marine Railways
What About Fixed Ladders
Section 1915.72 addresses portable ladders, not permanently installed ones. OSHA’s general industry rule at 29 CFR 1910.23 contains the detailed fixed ladder specifications, including a seven-inch minimum toe clearance, through-ladder side rails extending 42 inches above the access level with 24-to-30-inch flare clearance, and fall protection above certain heights.5Occupational Safety and Health Administration. 29 CFR 1910.23 – Ladders Where Subpart E of Part 1915 provides a specific shipyard rule, it generally takes precedence over the general industry standard. For fixed ladders that Subpart E does not address, consult OSHA to confirm which standard governs your site.
Penalties for Violations
OSHA enforces the shipyard ladder standard using the same penalty structure that applies across all industries. A serious violation, one where the employer knew or should have known of a hazard likely to cause death or serious physical harm, carries a maximum fine of $16,550 per violation under the most recently published schedule. Willful or repeated violations can reach $165,514 each.6Occupational Safety and Health Administration. OSHA Penalties These amounts are adjusted annually for inflation, so check OSHA’s current penalty page before relying on a specific figure.
Failure-to-abate penalties, assessed when a cited hazard is not corrected by the deadline, run up to $16,550 per day past the abatement date.6Occupational Safety and Health Administration. OSHA Penalties One unsecured ladder or one missing gangway railing can look minor in isolation, but each deficient ladder or unguarded access point counts as its own violation, and citations at a shipyard with several access points add up fast.