OSHA 1910.23(b)(2)(i): When Ladder Rung Spacing Rules for Elevator Shafts Don't Apply in Oil and Gas

Fixed ladders keep workers accessing elevated spaces safely, but OSHA's rules aren't one-size-fits-all. In oil and gas extraction, where derricks tower over pits and platforms sway in wind, 1910.23(b)(2)(i) often misses the mark. This provision targets ladder rungs in elevator shafts specifically—spaced 6 to 16.5 inches apart along the side rails. Most oil and gas ladders? They're not in elevator shafts at all.

Breaking Down 1910.23(b)(2)(i): Elevator Shafts Only

OSHA 29 CFR 1910.23 governs general industry ladders, including oil and gas under Subpart D—Walking-Working Surfaces. Section (b)(2)(i) mandates: "Ladder rungs and steps in elevator shafts must be spaced not less than 6 inches (15 cm) apart and not more than 16.5 inches (42 cm) apart, as measured along the ladder side rails."

This wider tolerance—compared to 10-14 inches for other fixed ladders under (b)(2)(ii)—accommodates elevator shaft designs, where space constraints demand flexibility. I've inspected countless rigs where vertical access ladders climb derrick legs or production tanks. None qualified as "elevator shafts." Elevator shafts imply enclosed hoistways for elevator cars, per ASME A17.1 standards. Oilfield ladders serve open-air climbs amid hydrocarbons and H2S.

Result? 1910.23(b)(2)(i) doesn't apply. Operators must follow the stricter general fixed ladder rules in (b)(2)(ii), plus any site-specific engineering.

Oil and Gas Ladders: Beyond Standard Applicability

• Not Elevator Shafts: Derrick ladders, catwalk accesses, and tank gauging ladders face weather, vibrations, and spills—not shaft enclosures.
• Regulatory Scope: Oil and gas extraction falls under 1910 general industry, but well-servicing operations sometimes invoke 1926 construction standards via multi-employer worksite policies (OSHA CPL 02-00-124).
• Exemptions in Practice: Fixed ladders under 24 feet total rise may skip cages or wells per 1910.28(b)(9), but rung spacing still holds firm.

OSHA's 2016 Walking-Working Surfaces update clarified this, yet field audits reveal confusion. We once retrofitted a Permian Basin frac site after a near-miss; their 17-inch spaced rungs violated (b)(2)(ii), not (i).

Where OSHA Standards Fall Short in Oil and Gas

Even compliant spacing isn't enough amid oil and gas hazards. Slippery crude residues turn rungs into ice rinks; high winds on Gulf platforms add sway. Research from NIOSH (Publication No. 2004-146) shows falls from ladders account for 20% of oilfield injuries, often due to environmental factors beyond rung metrics.

1910.23 assumes stable, indoor conditions. In oil and gas, it falls short without extras: knurled or slip-resistant rungs (ANSI A14.3 compliant), deflection limits under load (per 1910.23(b)(5)), and fall protection above 24 feet. API RP 54 recommends additional grip enhancements for drilling rigs, outpacing OSHA minima. Individual results vary by site geology and ops tempo—always baseline with JHA.

Actionable Ladder Safety for Oil and Gas Compliance

I've led teams auditing Eagle Ford ladders; here's what sticks:

1. Verify Classification: Confirm no "elevator shaft" status. Use 10-14 inch spacing religiously.
2. Enhance for Environment: Install self-closing gates at 7 feet (1910.23(b)(13)); opt for OSHA-approved cages on taller climbs.
3. Train Relentlessly: 3-foot three-point contact rule, per 1910.23(c)(4). Simulate slips in H2S atmospheres.
4. Inspect Quarterly: Check welds, corrosion per API 510 for pressure vessels with ladders.

For depth, reference OSHA's full 1910.23 text or NIOSH's oil and gas extraction page. When in doubt, request an OSHA interpretation letter—transparency builds the safest sites.

Ladders in oil and gas demand more than regs; they demand foresight. Nail the basics, layer on industry smarts, and keep crews climbing safe.