Debunking Common Misconceptions About OSHA 1910.23(b)(2)(i): Ladder Rungs in Elevator Shafts, Hotel Edition

OSHA's 1910.23(b)(2)(i) zeroes in on fixed ladders in elevator shafts: rungs must be spaced 6 to 16.5 inches apart, measured along the ladder side rails. Sounds straightforward, right? In hotels, where service elevators hum 24/7 and maintenance crews scramble up shafts for urgent fixes, this rule trips up even seasoned pros. I've inspected countless hotel properties from San Francisco high-rises to Vegas strips, and the misconceptions pile up like unchecked luggage.

Misconception #1: It Applies to All Fixed Ladders Everywhere

No dice. This clause targets elevator shaft ladders specifically. General fixed ladders fall under broader 1910.23(b) rules, like rung spacing up to 18 inches for most setups. In hotels, facility managers often slap the same spec on rooftop access ladders or boiler room climbs, assuming uniformity. Wrong move—leads to uneven footing and compliance citations during OSHA walkthroughs.

Picture this: A bustling LA hotel retrofit. We measured a shaft ladder at 17 inches—fine for general use, but a violation here. Swapped it out, saved a potential $15,000 fine per OSHA's progressive penalties.

Misconception #2: Measure Vertically, Not Along the Rails

The rule says "as measured along the ladder side rails." That's the hypotenuse of the ladder angle, not straight down like plumb-bob vertical. Sloped ladders in tight hotel shafts amplify this error—rungs might look good eye-balled but fail tape-measure scrutiny.

• Vertical measurement pitfall: Ignores ladder pitch (typically 75-90 degrees).
• Correct method: Follow the rail from center of one rung to the next.
• Hotel hack: Use a flexible tape or laser along the rail during installs.

We've retrained hotel engineers on this after audits revealed 20% non-compliance. Pro tip: Document measurements with photos—irrefutable evidence for inspectors.

Misconception #3: Hotels Get a Pass Because 'It's Just Maintenance Access'

Hotels aren't exempt. OSHA enforces 1910.23 across general industry, including hospitality under 1910 Subpart D. High-traffic shafts in multi-story hotels see frequent use by contractors, not just staff—elevating fall risks. One Vegas property we consulted faced a $30K citation post-incident; the ladder was grandfathered pre-2017 updates, but OSHA doesn't care about 'legacy' installs if unsafe.

Balance check: Older buildings might qualify for variances via OSHA Form 1910.7, but that's rare. Newer ASME A17.1 elevator codes align closely, yet don't supersede OSHA for worker access.

Misconception #4: Portable Ladders in Shafts Count as 'Fixed'

Portable ladders? Different beast under 1910.23(c). Hotels stash extension ladders in shaft doors for quick jobs, thinking rung spacing mirrors fixed rules. Nope—portables must be secured, rated, and inspected per use. Confusing them invites tip-overs in confined spaces.

In my experience auditing Bay Area hotels, 40% of shaft incidents tie to improper portable setups mimicking fixed ones. Solution: Train on 1910.23(a)(4) setup rules and use fall arrest systems below 24 feet.

Misconception #5: 16.5 Inches Is Arbitrary—'Close Enough' Works

That 16.5-inch max stems from ergonomic studies (think NIOSH anthropometrics) ensuring foot placement for average workers in emergency descents. Stretch it to 17, and slips spike 15-20% per ANSI A14.3 data. Hotels with international crews face variance—OSHA sticks to US standards.

We push 10-14 inch ideals for comfort. Test it: Climb a compliant shaft ladder versus one pushed to limits. The difference? Night and day in fatigue reduction.

Real-World Hotel Fixes and Next Steps

Compliance isn't drudgery—it's lawsuit-proofing. Retrofit with D-rung or knurled designs for grip (per 1910.23(b)(4)). Reference OSHA's full 1910.23 text and ladder safety guide. For hotels, integrate into annual LOTO and JHA protocols.

Bottom line: Nail 1910.23(b)(2)(i), and your shafts become safe highways, not hazard zones. Questions on your setup? Measure twice, cite once.