Safety Knights

At first glance, before I noticed the degrees, I thought that was actually ship stairs, but ship stairs can't exceed 70°, so that ruled that out once I looked at the details.

With that being said, I would consider this a fixed ladder since it's part of the structure. Although it moves side-to-side, you cannot pick this ladder up and move it somewhere else in the facilty without unbolting it. The fact that it's an integral part of the structure/equipment is a main deciding factor as to whether it's fixed or portable.

Great question! I could definitely see how it could be interpreted either way.

Cannot argue with Drew's logic. Sometimes I feel like an "echo". In my opinion it is "fixed" but more importantly it is definitely a "ship's ladder."

About 10 years ago I was doing a very similar project as mandated by corporate EHS. At the time OSHA had emphasis programs going on with regards to ladder inspection. As I was doing process I found two fixed stairs on a newer set of robotic forming machines with stairs with very steep angles to the horizontal. They were obviously in excess of 50 degrees (these were about 65) the OSHA limit for normal stairs in 1910.25. I was particularly concerned because these stairs had slipped passed me on these new machines. I had never been consulted on the safety of the machines in the first place. Also the design of these stairs was not necessary as there was plenty of floor space to have constructed normal safer stairs.

Like you did I a lot of research. First I came upon 1925(e) that describes "ship's ladders". it is not a lot so I did more research. I suggested to Ops to install normal stairs as operators were going up the stairs very often during a shift. The raised platform was above the machines was about 20'. They did not like the price of $10K per stair system. So I did more research and instituted more controls including:

#1 Increased training to require annual ladder training for the employees using these stairs.
#2 Mandated "3-points of contact" while going up these stairs. Did not allow tools or anything in the operators hands while going up or down the stairs.
#3 Posted "Hazard Signage" notifying all employees that these were not normal stairs, and restricting access to only those machine operators that needed to go on top of the machines.

Seemed like I got this information somewhere within OSHA.

I also embraced MOC after that! Implemented procedures to be involved with machine procurement and inspection and approval of all equipment entering the facility.

OSHA Regs state:

Fixed ladder means a ladder that cannot be readily moved or carried because it is an integral part of a building or structure. A side-step fixed ladder is a fixed ladder that requires a person getting off at the top to step to the side of the ladder side rails to reach the landing. A through fixed ladder is a fixed ladder that requires a person getting off at the top to step between the side rails of the ladder to reach the landing.

Portable ladder means a ladder that can be readily moved or carried.

I would say that the key word here is "moved"
https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.1050