Egress starts at 4 ft
Under 29 CFR 1926.651(c)(2), a trench excavation 4 ft (1.22 m) or more deep must have a stairway, ladder, ramp or other safe means of egress. The trap: 5 ft is the protective-system trigger in 1926.652, not the egress trigger. Neither 3 ft nor 6 ft appears in the rule.
The 25 ft travel limit
The same paragraph requires egress located so that workers travel no more than 25 ft (7.62 m) laterally to reach it. The trap: 25 ft is the maximum sideways walk for a worker, not a fixed spacing between ladders.
In an 80 ft trench 4-1/2 ft deep with one ladder at the east end, a worker at the west end walks 75 ft. That violates the rule, so more egress must be added. One ladder does not comply when a worker is 75 ft from it, and the 4-1/2 ft depth is over the 4 ft trigger.
Spoil and equipment: 2 ft back
1926.651(j)(2) covers spoil, materials and equipment that could fall or roll into the excavation. Three methods comply:
- Keep them at least 2 ft (0.61 m) from the edge.
- Hold them back with retaining devices.
- Use a combination of both.
Spoil piled 18 in. from the edge with no retaining device falls short. Retaining devices alone are acceptable. The trap: 1 ft is less than the rule requires, and 5 ft is the protective-system depth, not a setback.
Inspections by a competent person
1926.651(k)(1) requires a competent person to inspect the excavation, the adjacent areas and the protective systems:
- daily, before work starts;
- as needed throughout the shift;
- after every rainstorm or other hazard-increasing occurrence.
So a morning inspection does not cover the day if a heavy rainstorm passes at midday: the crew needs a new inspection of the excavation, adjacent areas and protective systems before going back in. The trap: the rule assigns inspections to a competent person, not a registered professional engineer.