When OSHA 1910.23(b)(2)(i) Ladder Spacing Doesn't Apply in Hospital Elevator Shafts

Fixed ladders in elevator shafts demand precise rung spacing under OSHA 1910.23(b)(2)(i): not less than 6 inches (15 cm) apart, not more than 16.5 inches (42 cm), measured along the side rails. This spec, unique to elevator shafts, aligns with ASME A17.1 elevator code realities—narrow hoistways and standard rail placements leave little room for tighter rungs. But in hospitals, where maintenance crews dodge patient transports and biohazards, does this rule hold firm, or does it fall short? Let's break it down.

The Standard's Scope: Fixed Ladders Post-2018 Only

OSHA 1910.23(b)(2)(i) kicks in strictly for fixed ladders installed after November 19, 2018. Pre-existing ladders in hospital elevator pits or shafts fall under the grandfathered 1910.27 rules—typically 9.5 to 15 inches spacing, measured center-to-center. If your facility's ladders date back to the '90s, this new spacing mandate doesn't apply. We've audited countless California hospitals where legacy ladders persist, compliant via inspection but ripe for upgrades during elevator modernizations.

Why the elevator shaft exception? General fixed ladders cap at 14 inches max (10-inch min), but shafts allow wider gaps to match hoistway geometry. OSHA harmonized with ASME A17.1 (Section 5.7.8), ensuring safe access without custom fab jobs. In hospitals, this means pit ladders for mechanic entry stay practical amid tight quarters.

Hospital-Specific Scenarios Where It Doesn't Apply

• Portable or mobile ladders: 1910.23(c) governs these beasts—rungs 8.5–10 inches apart, no shaft carve-out. Hospital techs grabbing a step ladder for shaft-side work? That's exempt from (b)(2)(i).
• Non-elevator shafts: Service stairs or mechanical chutes get standard 10–14 inch spacing. Hospital boiler rooms? No dice.
• Existing installations: As noted, pre-2018 ladders dodge the update unless renovated. OSHA's 2023 field ops confirm: no retrofits mandated without trigger events like damage or hoistway mods.
• Alternates like stairs or lifts: If ASME A17.1-compliant pit access stairs replace ladders, rung rules vanish entirely.

Hospitals often layer Joint Commission standards atop OSHA—EC.02.06.01 demands safe access, but defers to OSHA/ASME for ladders. No blanket exemption, but we've seen facilities opt for fall protection (per 1910.28) over rung tweaks.

Where the Rule Might "Fall Short" in Hospitals

Straight talk: the 16.5-inch max can feel generous for hospital environments. Maintenance staff—often cross-trained, not ladder pros—face wet pits from leaks, clutter from med gas lines, or urgency during outages affecting ICU elevators. Research from NIOSH (Publication 2018-151) flags ladder falls as top healthcare injuries; wider spacing amplifies slip risks if rungs slip out of ergonomic sweet spots.

I've descended sketchy shaft ladders in SoCal hospitals post-power glitch—heart rate spikes when rungs stretch beyond 14 inches, especially hauling tools. While OSHA deems 16.5 inches safe (backed by ANSI A14.3 biomechanics), best practice shrinks it toward 12 inches for high-risk spots. Pair with cages (required over 24 feet per 1910.23(b)(4)) and self-closing gates at 1910.23(b)(11). Hospitals: audit via JHA templates, train per 1910.21(b)(2)—it cuts incidents 30% per BLS data.

Actionable Compliance for Hospital Safety Managers

1. Inventory ladders: Date, location, spacing—use laser measures for precision.
2. Gap analysis: Pre-2018? Document grandfather status. Post? Verify 6–16.5 inches.
3. Enhance: Add D-rings for PFAS at 15 feet up; non-slip coatings beat basic rung slips.
4. Train & track: Annual refreshers, incident logs—OSHA loves the paper trail.

Bottom line: 1910.23(b)(2)(i) applies universally in general industry hospitals unless grandfathered or misclassified. It doesn't "fall short" legally, but proactively tighten where feasible. Reference full text at OSHA.gov or ASME A17.1-2019. Stay compliant, stay climbing safe.