Figure 2: Improper practice - Ships ladder blocked by hoses and equipment.
 
Figure 3: Improper practice - Worker on ladder that may shift or slip.
 
Figure 4: Improper practice - Fixed ladder extending out of an enclosed space with less than 4-inch clearance behind the ladder rung.

• Ship's ladders are often damaged or slippery.
• Ship's ladders are often blocked by cargo or materials.
• Cargo or materials are being moved while workers are using the ladder.
• Portables ladders may shift or slip.

Requirements and Example Solutions:

• One safe and accessible ladder must be provided for each cargo space. [29 CFR 1915.76(a)(1)]
• Fixed ladders that are visibly unsafe must not be used. [29 CFR 1915.76(a)(2)]
• Portable ladders must be used when ship's ladders are visibly unsafe. [29 CFR 1915.76(a)(3) and 29 CFR 1915.72]
• Fixed ladders must have a 4-inch clearance behind the ladder rungs. [29 CFR 1915.76(a)(4)]
• Material or cargo must not be moved while workers are using access ladders. [29 CFR 1915.76(a)(5)]

Figure 5: Ventilation duct passing through access opening.


Figure 6: Access to confined space blocked by ventilation hoses. (Improper practice if only access.)

• Limited egress from the space may be blocked.
• There may be only one means of egress from the space.

Requirements and Example Solutions:

• More than one means of access must be provided to a confined space unless the structure of the vessel makes it impractical. [29 CFR 1915.76(b)(1)]
• When the ventilation ducts must pass through the means of access, ducts must allow for free passage. [29 CFR 1915.76(b)(2)] See Figure 2.
  • Note: When there is only one means of access, collapsible ducts may be used to provide access.
• If ventilation equipment blocks access to the space, airline respirators as well as a stand-by employee must be used. [29 CFR 1915.51(c)(3)]
• Frequent checks must be conducted to ensure the safety of employees working alone in a confined space. [29 CFR 1915.94]