NR 35: contributing to Annex III

by | 22/05/2018

Today instead of giving tips and instructions about equipment and techniques for working at height, I decided to post the information about Annex III (ladders) of NR35, which was released on April 16 this year and is up for public consultation until next June 15.
This annex tries to fill an important gap when the subject is safety in activities with ladders.

Today the market is quite lacking and with very confusing information, from the manufacture of the ladders, their correct use, maintenance, fall protection system, fixed, mobile, etc.
That is why this announcement comes at a good time. And this is the chance for you to participate, by analyzing and giving suggestions for improvement!

Find below the text that is available for consultation on the Ministry of Labor’s website.
We at Hércules would like to know what is your opinion about Annex III. Share your view on this subject with us!

Annex III (Ladders) of NR-35
SIT Ordinance No. 712, April 12, 2018

1 – Field of application

1.1 – For the purposes of application of this annex, ladders can be classified as individual and collective use.

1.2 – This annex establishes the safety requirements for the use of individual ladders as a means of access or workstation where the worker is positioned at a level higher than two meters.

1.2.1 – Excluded from this annex are ladders for collective use, which are those used permanently or temporarily as a means of circulation by more than one worker at the same time, connecting different levels of a building.

1.3 – For the purposes of this Annex, individual ladders may be fixed or portable.

1.3.1 – Portable ladders may be back-up or self-supporting.

1.3.1.1 – Recessed ladders may be of fixed length or extendable.

1.4 – This appendix does not change the specific requirements established in the other regulatory standards on the subject, respecting the field of application of each standard.

1.5 – The use and manufacture of individual ladders should meet the requirements of this annex and, complementarily, the national technical standards or, in their absence, the international standards.

2 – Individual ladders

2.1 – The selection of individual ladders as a means of access and place for working at height should be preceded by risk analysis, in accordance with sub-item 35.4.6.

2.1.1 – The risk analysis shall consider:

a – whether a given task can be safely performed from a ladder or another means should be used.

b – that the type of ladder and its characteristics are adequate for the access or the task to be carried out.

2.2 – The training referred to in sub-item 35.3 should include the safe use of individual ladders for workers who use them as a means of access or workplace.

2.3 – The individual ladders should meet one of the following requirements:

a – be certified;

b – be manufactured in accordance with the national technical standards in effect under the responsibility of a legally qualified professional;

c – be designed by a legally qualified professional, with the national technical standards in force as a reference.

2.4 – The individual staircases must: (Note: In the PDF or DOC file, the subparagraphs of this item appear after subparagraph “f” of item 2.4.2)

2.4.1 – The procedure or basic instructions for use shall contain: (Note: In the PDF or DOC file, the sub-items in this item appear right after sub-item 2.4.1.1)

2.4.1.1 – When portable ladders are transported by racks or in vehicles, it should be ensured that they are properly secured with lashings to prevent damage.

a – the instructions for use; (section belonging to sub-item 2.4.1)

b – the maximum work load; (section belonging to sub-item 2.4.1)

c – the limitations of use; (section belonging to sub-item 2.4.1)

d – warnings about incorrect use; (section belonging to sub-item 2.4.1)

e – when it comes to portable ladders, the correct procedure for safekeeping, storage, and transportation. (section belonging to sub-item 2.4.1)

2.4.2 – The marking should contain

a – identification of the manufacturer;

b – month and year of manufacture and/or serial number;

c – indication of slope, when not obvious due to its construction and design;

d – maximum number of simultaneous users

e – the ladder’s weight;

f – electrical insulation, if any.

a – resistance the loads applied; (section belonging to item 2.4)

b – be built with materials and finishing that do not cause injuries to the user during use; (section belonging to item 2.4)

c – have a procedure developed by the company or instructions for use, by manual or electronic media provided by the manufacturer; (Subparagraph belonging to item 2.4)

d – have a marking with the manufacturer’s data and basic warnings for use; (section belonging to item 2.4)

e – if made of wood, the parts must be flattened on all sides and in case of application of coating, this must be transparent, making it easy to detect imperfections. (section belonging to item 2.4)

2.5 – Individual ladders should be used by one person at a time, except when specified by the manufacturer for simultaneous use.

2.5.1 – At all times when using individual ladders, the worker must be supported by three points of support.

2.5.2 – The transportation of materials must be done by appropriate means when using ladders that require the use of hands as a support point for access or work.

2.5.2.1 – The transportation of materials by appropriate means is considered to be carried out by using independent means or when the materials are stored in containers that do not compromise the worker’s support points.

2.6 – Ladders, when used as a workplace at a height of more than two meters, must be equipped with a fall protection system.

2.6.1 – The vertical lifeline of the fall protection system installed on the ladder itself cannot be used simultaneously by more than one user, except in rescue situations.

2.7 – According to a risk analysis, the use of fall protection systems may not be required in stairways less than 3.5 meters (three meters and fifty centimeters) when used only as a means of access.

2.7.1 – In these cases, the training provided for in sub-item 35.3 can be replaced by theoretical and practical training, and the workload and content can be established according to the situation that motivated it.

3 – Fixed Individual Ladders

3.1 – The fixed ladders, sailor type, should:

a – support the requested efforts;

b – if external, made of weather-resistant materials;

c – be between 0.4m (forty centimeters) and 0.6m (sixty centimeters) wide;

d – have spacing between the steps between 0.25m (twenty-five centimeters) and 0.3m (thirty centimeters);

e – have a handrail or a continuation of the stair risers going beyond the top floor or resting platform, with a height between 1.10m (one meter and ten centimeters) and 1.20m (one meter and twenty centimeters);

f – be at a distance of at least 0.15m (fifteen centimeters) from the structure on which it is fixed.

3.2 – The use of fixed ladders, of the sailor type, with a single flight over 10.0m (ten meters) high, is forbidden.

3.3 – Fixed ladders that are higher than 10.0m (ten meters) must have multiple flights with the following characteristics:

a – have a maximum height of 6.0m (six meters) for each flight;

b – have resting platforms between each flight;

c – flights must be arranged in parallel axes, at least 0.70m (seventy centimeters) apart.

3.4 – Cages are not considered fall protection systems.

4 – Portable Individual Ladders

4.1 – Portable ladders should be restricted to the access of workers and small services of short duration.

4.2 – It is forbidden to place portable ladders near doors or circulation areas, openings and spans and in places where there is a risk of objects or materials falling, except when a protection measure has been adopted.

4.3 – The portable ladder should be selected:

a – according to the projected load, in order to resist the weight applied during access or execution of the task, worker, equipment and materials;

b – considering the efforts when using fall protection systems;

c – considering rescue situations.

4.4 – The portable individual ladders should be supported on a stable floor and have non-slip bases (shoes), appropriate to the nature of the floor.

4.5 – The portable ladders shall be inspected: (Note: In the PDF or DOC file, the sections in this sub-item appear after sub-item 4.5.1.1.1)

4.5.1 – In case of problems or imperfections likely to compromise the performance of portable ladders, they should be removed from use.

4.5.1.1 – When recoverable, portable ladders should be repaired by the manufacturer or a specialized company.

4.5.1.1.1 – Repairs which do not compromise the ladder’s structure may be carried out by a trained worker.

a – upon receipt or initial release for use; (Section belonging to item 4.5)

b – before use; (Section belonging to item 4.5)

c – periodically, according to the manufacturer’s recommendations. (Section belonging to item 4.5)

5 – Single-rung portable ladders

5.1 – The use of single-rung portable ladders should follow the following recommendations: (Note: In the PDF or DOC file, the sections of this item appear after section “b” of sub-item 5.1.1)

5.1.1 – In the case of extendable ladders, they shall

a – be fixed at more than one point;

b – the guides and locks shall be kept in good conditions.

a – be fixed to a sturdy, stable structure at least at one point, preferably the upper level; (Section belonging to item 5.1)

b – have the base supported at a distance between 1/3 (one third) and 1/5 (one fifth) in relation to the height, inclined between 70 and 80 degrees, or according to the manufacturer’s recommendations; (Section belonging to item 5.1)

c – when used for access, be positioned so as to exceed the upper level by at least 1.0 m (one meter); (Section belonging to item 5.1)

5.2 – Single-rung portable ladders should be equipped with limiting brackets, placed in the fourth span from the ratchet.

5.2.1 – The ladders that do not have the limiting brackets should have an alternative mechanism that ensures a minimum overlap of one meter between the flights when fully extended.

6 – Self-supporting Portable Ladders

6.1 – The use of self-supporting ladders should follow the following recommendations:

a – only use the self-supporting ladders with the limiters fully functioning and in the positions indicated by the manufacturer;

b – only use the self-supporting ladders as a place for working at height, never using them as a means of access to higher levels;

c – the use of tools for the execution of services must not compromise the stability of the ladder and, if supported by the ladder, they must be protected against falls.

7 – Glossary

– Maximum Working Load: the maximum weight the ladder is designed to support when configured in accordance with the manufacturer’s instructions.

a – Maximum Work Load: maximum weight that the ladder is designed to support when configured in accordance with the manufacturer’s instructions.

b – Locking device: device which keeps the flights engaged during use (hook, ratchet).

c – Self-supporting ladder: also known as opening ladder is a self-supporting ladder with two flights and unilateral or bilateral access, with or without platform, with or without support handle.

d – Portable ladder: ladder that can be carried and assembled by hand.

e – Opening limiter: device for self-supporting ladders that limits the ladder’s opening.

f – Footings: device fixed to the underside of ladders to prevent them from slipping. In the case of wooden ladders, the shoe is the foot of the upright itself.

g – User: the person who uses the ladder.