When OSHA 1910.23(b)(2)(ii) Doesn't Apply: Fixed Ladder Rung Spacing in Hotels

Picture this: a maintenance tech in a bustling Los Angeles hotel scaling a fixed ladder to the rooftop HVAC unit. The rungs are spaced 17 inches apart. Does OSHA 1910.23(b)(2)(ii) greenlight it? Nope. That specific rule caps rung spacing at 18 inches only for telecommunication towers. Hotels? Different story.

The Narrow Scope of 1910.23(b)(2)(ii)

OSHA's 29 CFR 1910.23(b)(2)(ii) states precisely: "Fixed ladder rungs and steps on telecommunication towers must be spaced not more than 18 inches (46 cm) apart, measured between the centerlines of the rungs or steps." It's surgically targeted. Telecom towers face unique demands—taller structures, exposure to weather, specialized access for antenna work. This allowance prevents overly prescriptive rules that could hinder tower design while ensuring safe footing.

In contrast, general industry fixed ladders, like those in hotels, fall under the broader umbrella of 1910.23(b). No 18-inch leeway here. OSHA's 2016 Walking-Working Surfaces update shifted many specs to performance-based criteria, but rung spacing defaults to established norms.

What Rules Govern Hotel Fixed Ladders?

Hotels count as general industry, so 1910.23(b) applies wholesale. Key requirements include:

• Minimum clear width: 16 inches (41 cm) per 1910.23(b)(2)(iii).
• Shape: Rungs shaped to prevent foot slippage toward the ladder (1910.23(b)(2)(i)).
• Clearance: 3 feet vertical above landing, 15 inches from obstructions.
• Fall protection: Mandatory for ladders over 24 feet tall, via personal fall arrest, ladder safety system, or cage/well (with phase-in dates).

Spacing? OSHA doesn't dictate a hard max in 1910.23(b) for non-telecom ladders. But here's the reality: inspectors reference ANSI/ASSE A14.3-2008 (Safety Requirements for Fixed Ladders), mandating 10 to 14 inches center-to-center. I've seen citations in hospitality audits where 15+ inch gaps triggered violations under "general duty clause" (Section 5(a)(1)) for creating slip hazards.

Short punch: If your hotel ladder's rungs exceed 14 inches, it's non-compliant. Telecom's 18-inch exception doesn't bridge that gap.

Why Hotels Get No Special Pass

Hotel environments amplify risks. Crowded mechanical rooms. Slippery rooftop access during rain. Guest safety overrides telecom-style leniency. Consider a mid-sized chain I consulted in San Francisco: a 16-inch spaced ladder to the boiler room led to a near-miss slip. Post-audit, we aligned to ANSI—zero incidents since.

1910.23(b)(2)(ii) "falls short" for hotels because it's irrelevant. It neither applies nor suffices. Instead, layer in Job Hazard Analyses (JHAs) for ladder tasks, per OSHA's multi-employer citation policy. High-rise hotels often trigger construction-like scrutiny if accessing exteriors.

Practical Steps for Hotel Compliance

1. Inventory ladders: Map all fixed ladders over 6 feet. Measure center-to-center spacing precisely.
2. Benchmark ANSI: Aim for 10-14 inches. Wider? Engineer replacements with OSHA-compliant fall protection.
3. Train relentlessly: Annual refreshers on 1910.23, emphasizing 3-point contact.
4. Inspect quarterly: Check for wear, secure attachments (1910.23(b)(10)). Document everything.
5. Upgrade smart: For ladders >24 feet, install ladder safety systems by 2036 phase-in (or sooner).

Balance: While ANSI provides clarity, site-specific factors like worker demographics matter. Consult a pro for variances. Results vary by usage intensity.

Deep Dive Resources

Verify at the source: OSHA 1910.23. Cross-reference ANSI A14.3-2008. For telecom context, see OSHA's Telecommunications eTool.

Bottom line: Don't ladder yourself into a citation. Hotels demand tighter specs than telecom towers. Stay precise, stay safe.