OSHA 1910.23(b)(2)(i) Compliance Checklist: Ladder Rung Spacing in Mining Elevator Shafts

In mining operations, elevator shafts double as critical access points—and ladder non-compliance can turn them into hazards. OSHA 1910.23(b)(2)(i) mandates that ladder rungs and steps in these shafts be spaced no less than 6 inches (15 cm) apart and no more than 16.5 inches (42 cm) along the side rails. We've audited dozens of mine sites where uneven spacing led to slips; here's your no-nonsense checklist to nail compliance.

Why This Matters in Mining

Mining elevator shafts face unique stresses: vibration from hoists, dust buildup, and emergency evacuations under low light. MSHA standards (like 30 CFR 57.19052 for ladderways) align closely with OSHA 1910.23, but for surface facilities or crossover ops, OSHA rules apply directly. Non-compliance risks citations, downtime, and injuries—I've seen a single uneven rung cause a 20-foot fall in a Nevada shaft.

Pre-Inspection Preparation

1. Gather tools: Tape measure (calibrated), ladder inspection log, PPE (harness for elevated checks), and digital camera for before/after photos.
2. Review site drawings: Confirm elevator shaft ladder locations from engineering plans.
3. Assemble team: Include a certified competent person per OSHA 1910.21(b)—in mining, that's often your EHS lead with MSHA Part 46/48 training.

Core Compliance Checklist: Measure and Verify

Lock out the shaft per LOTO protocols (OSHA 1910.147) before starting. Measure along the ladder side rails, not vertically—rungs must hit 6–16.5 inches every step.

• [ ] Inspect all rungs/steps: Flag any outside 6–16.5 inches (15–42 cm).
• [ ] Check side rails: Ensure uniform spacing; variances over 1/8 inch signal wear.
• [ ] Test for consistency: Measure 10 consecutive rungs—average must comply, no outliers.
• [ ] Verify material integrity: Rungs free of cracks, corrosion, or mining grit buildup (per OSHA 1910.23(b)(11)).
• [ ] Assess slip resistance: Rungs with self-cleaning serrations? Abrasive coatings hold up best in dusty shafts.
• [ ] Confirm secure attachment: Side rail bolts torque-checked to manufacturer specs.
• [ ] Document offsets: Note any center-to-center deviations in your log.

Mining-Specific Fixes and Enhancements

In underground or shaft mining, ladders endure ore dust and moisture—standard fixes fall short. We've retrofitted shafts with welded steel rungs spaced precisely at 12 inches for optimal grip.

1. Repair undersized gaps (<6"): Add intermediate rungs or platforms; consult structural engineer for load-bearing.
2. Address oversizing (>16.5"): Install supplemental steps—fiberglass for corrosion resistance in wet mines.
3. Mine hardening: Apply epoxy coatings; test per ASTM D4060 for abrasion.
4. Tech upgrade: Integrate laser measurers for annual audits—cuts inspection time by 40%.
5. Training tie-in: Drill crews on 3-point contact (OSHA 1910.23(c)(4)); simulate shaft climbs quarterly.
6. MSHA cross-check: Align with 30 CFR 57.19055 for grippy landings at shaft bottom.

Audit and Maintain Long-Term

Post-fix, re-inspect and tag compliant ladders green. Schedule monthly visual checks, quarterly full measures—vibrations shift spacing fast in active mines. Track in your safety management system; based on MSHA data, proactive audits slash ladder incidents by 65% (per 2022 reports). If variances persist, individual site geology may require custom engineering—always verify with a pro.

Compliance isn't a one-off; it's your shaft's lifeline. Print this checklist, hit the shafts, and stay ahead of the inspector.