In recent years we have been seeing an increasing trend for facilities to relocate equipment to their rooftops.  We suspect this is being done for two primary reasons: 1) it is free real estate and 2) it gets sensitive equipment away from  forklifts, scissor lifts, manlifts, and other motorized equipment.  Either reason we support; however, these businesses may be creating a compliance issue that may come back to bite them.

The refrigeration industry is one in particular where we have seen major projects in the last 5 years to move all ammonia piping and associated valves to the roof of the building(s) being refrigerated.  This is a very good move from the process safety perspective, as a forklift can be an ugly enemy to ammonia piping!  However, as you can surmise from me writing this article, this can often times create some other matters that need to be addressed. SAFTENG has facilitated several PHA’s and other risk assessments where businesses have decided to move their piping and other associated equipment to their roof tops.  And in each one, we have always come across one small facility siting issue that often impacts emergency egress.  To better understand what this may mean to a facility, let’s examine 1910.24 Fixed Industrial Stairs, as this standard and its requirements take many by surprise. 

1910.24(b) states…

"Where fixed stairs are required." Fixed stairs shall be provided for access from one structure level to another where operations necessitate regular travel between levels, and for access to operating platforms at any equipment which requires attention routinely during operations.

As you can see, it is pretty clear that a process that places its piping and other components that require attention routinely during operations on a roof will be required to have fixed industrial stairs for access to their roof areas.  If the first portion of the section did not convince you, the second part provides more examples of when fixed industrial stairs are required…

Fixed stairs shall also be provided where access to elevations is daily or at each shift for such purposes as gauging, inspection, regular maintenance, etc., where such work may expose employees to acids, caustics, gases, or other harmful substances, or for which purposes the carrying of tools or equipment by hand is normally required.  (It is not the intent of this section to preclude the use of fixed ladders for access to elevated tanks, towers, and similar structures, overhead traveling cranes, etc., where the use of fixed ladders is common practice.)

Now I am sure someone would argue that their process does not meet any of these requirements; however, if your facility has a daily or shift rounds to be made (normal practice in PSM/RMP processes) we need industrial stairs to access the roof.  Even if we do not make daily/shift rounds, but workers have to go up on the roof to operate valves or perform maintenance on a regular basis then we are required to have fixed industrial stairs.

I would also point out that 1910.37 requirements come into play.  Many of you are probaby asking where is he going with this, as there is nothing in 1910.36 or .37 that requires stairs.  But there is…

1910.37(a)(3) Exit routes must be free and unobstructed. No materials or equipment may be placed, either permanently or temporarily, within the exit route. The exit access must not go through a room that can be locked, such as a bathroom, to reach an exit or exit discharge, nor may it lead into a dead-end corridor. Stairs or a ramp must be provided where the exit route is not substantially level.

But fixed ladders that meet 1910.27 may be used for “emergency egress” in some situations.  I like to refer to OSHA’s Standard Directive STD 01-01-012 - Application of 29 CFR 1910.27, Fixed Ladders, to Fixed Ladders Used in Emergency Situations(6/20/1983) to help explain when fixed ladders can be used as a means for emergency egress.  In this directive OSHA states…

This instruction provides performance criteria for fixed ladders used only as a means of access for fire fighters and other emergency personnel, or escape for employees in fire and other emergency situations.

1. Employers must establish and implement adequate administrative controls such as barricades and signs to prevent nonemergency use of fixed ladders which are meant for fire fighter use and emergency escape only.

2. In the event the employer does not provide adequate administrative controls such as barricades or signs and employees use an emergency ladder for other than its intended purpose, the employer may be appropriately cited under 29 CFR 1910.27.

3. Fixed ladders not equipped with cages, landing platforms, ladder safety devices, or other forms of employee protection, in some situations may be allowed as a means of access for fire fighters and other emergency personnel, or escape for employees in fire and other emergency situations. These guidelines are provided because it may be more hazardous to comply with 29 CFR 1910.27 than not to comply.

However, OSHA has stated in LOI’s that fixed ladders are NOT even acceptable as a secondary means of emergency egress (2/62004). 

Bottom line… install at least one set of fixed industrial stairs for workers to access roof areas.  And if we have a fixed ladder on the other side of the building, I would suggest it be labeled “emergency use only” and this way workers will have two (2) means to get off the roof in the event of an emergency.  Don’t forget to label BOTH the top and bottom of the ladder “emergency use only”.

I fully support moving “forklift targets” to the rooftop, but we have to consider all aspects of this change and ensure we are not creating other safety and compliance issues.  Moving the equipment to the rooftop is "safer for our equipment", but it also increases the risks to the workers who have to routinely access the equipment and do high risk activities with limited means of egress. Emergency egress is nothing to sneeze at, and it becomes doubly important when we have workers on a rooftop with highly hazardous chemicals.  Just something to consider if your business is considering this change or if they have already made the change we may need to revisit the project to ensure we have not created an egress issue.

Oh and by the way, you may need to cover the stairs if they are outside!  (1910.36(h)(2)

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