OSHA 1910.24(a)(6): Step Bolt Load Capacity in Food and Beverage Production
Step bolts on fixed ladders in food and beverage plants aren't just rungs—they're lifelines for maintenance crews accessing silos, tanks, and elevated mixers. OSHA 1910.24(a)(6) zeroes in on those installed before January 17, 2017, mandating that employers ensure each one supports its maximum intended load. Ignore this, and you're courting failures that cascade into slips, falls, or worse in high-moisture, high-traffic environments like breweries or bottling lines.
What Exactly Does 1910.24(a)(6) Require?
This subsection of OSHA's standard on step bolts and manhole steps is straightforward: pre-2017 installations must handle the heaviest load they're designed for, without exception. "Maximum intended load" means the combined weight of the worker, tools, PPE, and any foreseeable extras—like a 300-pound technician hauling a 50-pound valve wrench up a distillery ladder.
Unlike newer bolts under 1910.28, which demand 300 pounds minimum per step, this rule grandfathered older ones but ties compliance to proof of capacity. I've inspected countless facilities where faded installation tags were the only clue, forcing destructive testing or engineering calcs to verify.
Why It Matters in Food and Beverage Production
- CIP Systems and Wet Environments: In dairy or beverage plants, clean-in-place (CIP) cycles drench ladders. Corroded step bolts lose grip fast; a 2022 USDA report noted corrosion as a top ladder failure cause in food processing.
- Silo and Tank Access: Grain silos in malting ops or syrup tanks in canning lines often use step bolt ladders. Overloaded steps snap under harvest rushes, sending workers plummeting 20+ feet.
- High Turnover Maintenance: Seasonal spikes in craft breweries mean rushed hires climbing without load checks, amplifying risks.
OSHA data from 1910.24 citations shows food manufacturing nabbing 15% of ladder violations last year. Non-compliance? Fines start at $16,131 per serious violation, per 2024 adjustments, plus downtime from incidents.
Practical Compliance Checklist for Your Facility
Start with an audit. We once traced a near-miss in a winery to a 1980s step bolt rated for 200 pounds—until fermentation residue weakened it.
- Inventory Pre-2017 Bolts: Tag every fixed ladder install date. Use Pro Shield's LOTO platform to log digitally if you're streamlining.
- Test Capacity: Non-destructive methods like ultrasonic thickness gauging for corrosion; load-test samples per ASTM F2205 if tags are gone.
- Engineer Verification: Get a PE stamp on calcs showing ≥ intended load (often 2x safety factor). Reference ANSI A14.3 for fixed ladder design.
- Train and Inspect: Annual visual checks per 1910.23(d)(9); train on load limits via JHA modules.
- Retrofit Threshold: If bolts fail, swap to post-2017 compliant ones or cages per 1910.28(b)(9).
Balance here: Testing costs $500–$2,000 per ladder, but beats $1M+ litigation from a fall. Individual results vary by alloy and exposure—stainless beats carbon steel in brine-heavy plants.
Real-World Fixes and Resources
In a SoCal juice bottler I advised, we load-tested 47 step bolts; 12 needed replacement, averting a PSM audit nightmare. Proactive beats reactive.
Dive deeper with OSHA's full 1910.24 text or NIOSH's ladder safety pubs. For engineering, ASCE 7 load tables guide "intended load" calcs. Stay compliant—your crews depend on it.
