Resort Management must provide a safe work environment for its employees. This not only makes good business sense; it is also a moral and legal obligation. Legally the employer must provide a safe work place, be it for guest services, janitorial or lift maintenance personnel. The safety of lift maintenance personnel, in particular, can present some unique challenges for ski area management. Thanks to new regulations, this safety issue is now more clearly defined.
At the request of the ski areas, the safety enforcement division of federal and state governments, known as the Occupational Safety and Health Administration (OSHA), has clarified its position on fall protection for climbers of ski lift towers. Now, resort managers understand what is expected for compliance and the OSHA field compliance officers can clearly and consistently enforce the standards. OSHA’s compliance clarification is important in that it shows that today’s more user-friendly OSHA recognizes the uniqueness of the situation and as a result modified its climbing requirements to meet the ski industry’s needs while still maintaining a safe work environment.
Typically, a fixed ladder (versus a temporary ladder) of more than 20 feet in length requires a ladder cage or a ladder safety climbing system, according to OSHA. The ladders must also be at least 16 inches wide and have at least seven inches of toe clearance. A fixed ladder on a ski tower often has a smaller profile (i.e. narrower and/or closer to the tower) in order to reduce hazards for passing skiers. A large cage, similar to what you might see surrounding a water tower ladder, also would create a greater hazard, according to OSHA and the ski industry. Therefore, OSHA’s clarification for ski industry tower climbing compliance includes the following key points.
1) On all ski tower ladders over 20 feet in length, a ladder safety-climbing device or alternate means for 100 percent fall protection during ascent or descent can be used for full compliance. A ladder safety-climbing device consists of a cable or rigid rail system running the length of the ladder. The climber attaches to a sleeve mechanism on the cable or rail that slides up and down freely, but locks on to the carrier should the climber slip or fall. The ladder safety-climbing system operates without assistance from the climber during ascent and descent.
The alternate 100 percent fall protection system consists of a twin leg lanyard attached to the climber’s full body harness. The climber, during both ascent and descent, alternately attaches the lanyard legs to the ladder or structure. At least one lanyard leg must be attached at all times in order to maintain 100 percent fall protection. This method is more demanding on the climber, requiring constant connecting and disconnecting.
2) Ladders not meeting the 16-inch minimum width and seven-inch minimum toe clearance requirements can be climbed using a ladder safety-climbing device or the alternate 100 percent fall-protection system. Climber training is required for non-compliant ladders. The training includes hands-on climbing, as well as identification of specific tower ladders at the ski area that have inadequate toe clearances and widths.
3) For emergency situations (the ski area would need to prove an actual emergency existed), only a “qualified climber” could ascend or descend a tower without the use of some form of fall protection. Once the climber reaches the work position he/she must tie-off for fall protection.
4) Qualified climbers must be physically capable of climbing and performing related duties on a routine basis. The student must complete both classroom and hands-on training programs. While in training, climbing activities must be closely supervised and students must be protected by redundant safety equipment until successful completion of the course.
All OSHA field offices, including those in states that operate OSHA-approved State Plans, have been made aware of this clarification and are expected to carry out enforcement accordingly. Ski area managements, typically unaccustomed to OSHA rule enforcement, should review safety programs, make plans to procure the appropriate fall protection equipment for OSHA compliance and implement Qualified Climber Training. These measures will help to assure safe ascent and descent of ski towers and assist management in providing a safe work environment at the ski resort.
