When the Ladder Wins: Building a Reasoning Trail for Short-Duration Work at Height
Of all the access equipment on a UK site, the ladder is the item most likely to be used and least likely to be explained. It arrives in the back of a van, leans against a wall, and is gone before anyone has written a sentence about why it was there. That silence is the problem. The Work at Height Regulations 2005 do not prohibit ladders; they require that the selected equipment is suitable and that the choice can be justified against the hierarchy of control. A ladder used without a record of that reasoning looks like a default. A ladder used with one looks like a decision.
The scrutiny is about the reasoning, not the rung
Regulation 6 sets out the familiar sequence: avoid work at height where possible, prevent falls where it cannot be avoided, and mitigate the distance and consequences of a fall where prevention is not practicable. Regulation 7 then requires duty holders to consider risk, duration, distance, conditions, evacuation and rescue when selecting equipment. Short-duration, low-risk work is precisely the territory in which ladders are contemplated by both the Regulations and the published guidance from HSE and the Ladder Association.
The recurring failure is not the presence of a ladder. It is the absence of a documented exception. On too many sites the ladder is there because it was in the van, because the task was 'only five minutes', or because the MEWP was booked for the following week. None of those statements survives contact with an investigation.
Four questions before the ladder comes off the rack
A defensible exception rests on four questions, answered in writing before the first rung is climbed.
Is the task genuinely short? Duration must be expressed in minutes and the assumption stated. 'Low-level inspection of ceiling services, estimated fifteen minutes, single operative' is testable. 'Quick job' is not.
Is the risk genuinely low? Light tasks with no significant applied force, no awkward or heavy loads, no need to overreach and no foreseeable change in the work are the candidates. A task that will predictably expand — anything involving discovery, making good or a second trade — is not short-duration work, whatever the original intention.
Are the conditions genuinely stable? Ground bearing and level, weather, lighting, pedestrian and vehicle traffic, and the proximity of overhead services all bear on the decision. A ladder on a slope, a soft verge or a live loading bay is not the same proposition as one against an internal wall.
Is the alternative genuinely worse? This is the heart of the exception. It is not sufficient to say that no MEWP was available. The reasoning must show that the alternative would have introduced a greater risk or a disproportionate burden: a MEWP set up on a soft verge, a tower built in a stairwell with no landing space, a scaffold erected for a single light fitting. Where that argument can be made honestly, the ladder is defensible. Where it cannot, the ladder is simply convenient.
Selecting a ladder is part of the evidence
Class and duty rating matter. BS EN 131 ladders carry a duty rating, and industrial-duty equipment is the appropriate baseline for site use. The label should be legible and the rating matched to the task and the user. Condition is equally evidential: stiles free of cracks or bends, feet present and unworn, rungs secure, locking mechanisms and spreaders functioning, and no improvised repairs. A stepladder used in a folded, leaning configuration is only acceptable where the manufacturer explicitly permits it.
A ladder that fails these checks is not a lesser form of evidence; it is a finding in its own right.
Positioning and the pre-use check as recorded fact
A leaning ladder should sit at roughly seventy-five degrees, commonly expressed as one unit out for every four up. It should be secured against slipping where it is reasonably practicable to do so — tied off, fitted with a stability device, or otherwise restrained. Footing by a second person is a last resort, not a default.
Three points of contact should be maintained, and the user should avoid overreaching. The belt-buckle rule remains a useful discipline: if the buckle passes beyond the stiles, the user is too far out. The top three rungs of a leaning ladder, and the top two steps of a stepladder, should not be used as standing platforms unless the equipment is specifically designed for it.
The pre-use check should be recorded, not merely performed. A time, a name, a ladder identification number and a pass or fail against a short checklist converts an informal glance into a defensible fact.
The one-page reasoning trail
A workable ladder assessment fits on a single sheet and covers: the task and its expected duration; the load to be carried and the number of operatives; the surface and weather conditions; the alternative considered and the specific reason it was rejected; the ladder identification and inspection tag; the competence of the person using it; and the date and time. It should sit alongside the site's pre-use check record and, where the site operates a permit system, be cross-referenced to it.
Photographing the set-up is increasingly common on larger sites and costs little. It provides a contemporaneous record of angle, restraint and ground conditions that a written description struggles to match.
When the ladder should lose
There are clear circumstances in which the exception cannot be made: work of extended duration, tasks requiring both hands for significant periods, heavy or awkward loads, work near overhead lines, work on or near fragile surfaces, adverse weather, or any situation where rescue of an incapacitated user would be complex. In these cases the correct answer is a different piece of equipment, and the assessment should say so plainly.
Conclusion
A defensible ladder exception is not a ban and not a formality. It is a short, honest argument written down before the ladder is climbed, and it takes less time to record than most site inductions. If the argument takes longer to construct than the task takes to complete, that is itself useful information about the task.