First, I apologize for the delay in responding. I’m just returning from bereavement leave. This is a tricky question. Let me break it down.
1. Workers required to use fall protection must receive fall protection training.
2. Workers exposed to the risk of falling 3 metres/10 feet or more from a portable ladder do have to use fall protection–a personal fall arrest system (OHS Code, Sec. 137(1))
3. A case could be made that the worker standing in the middle of a portable ladder with his/her core only 6 feet above ground is NOT at risk of a 10-foot fall, in which case personal fall arrest and fall protection wouldn’t be required (I’m assuming that there’s no risk of the worker’s falling thru an opening or onto a hazardous substance or object, in which case fall arrest would still be required even if the fall is less than 10 feet (Sec. 139(1)(c))
4. Even if the fall would be deemed to be 10 feet or more, the Section 137(1) requirement for personal fall arrest wouldn’t apply if it would be not reasonably practical and: (a) the work is a light duty task of short duration at each location, (b) the worker’s centre of balance is at the centre of the ladder at all times even with an arm
extended beyond the side rails of the ladder, and (c) the worker maintains 3-point contact whenever the worker extends an arm beyond a side rail.
Bottom Line: From what you describe, especially the fact that the worker’s body will be in the center of the portable ladder well below the 3 metre/10 foot threshold at which fall protection is required is that you would NOT have to provide the worker fall protection and detailed fall protection training. Caveat: This is just a personal opinion and should in no way be considered legal counsel, which I’m neither qualified nor allowed to provide you. Still, it is an informed opinion. Sorry to go on so long and I hope this was worth the wait. Glenn
