The new OSHA General Industry fall protection regulations that went into effect this month are prompting a slew of questions on fixed ladders. If you are wondering when a fixed ladder requires fall protection, which forms of ladder fall protection are OSHA compliant, or if ladder cages still comply with OSHA’s revised ruling, we have just the post for you…..
If you carefully examine the new ruling, you’ll note that OSHA 1910.28(b)(9) requires General Industry employers to provide fall protection on fixed ladders more than 24′ above a lower level. This new requirement is important for a number of reasons. For starters, prior to the new ruling, the only real guidance on fixed ladders came from the Construction Standards– OSHA more (1926.1053(a)(18) required the use of cages, wells, ladder safety devices, or self-retracting lifelines for fixed ladders of 24 feet or more. OSHA’s new ruling was designed, in part, to create more uniformity between the General Industry and Construction standards. That said, the revised ruling also breaks new ground by creating a framework to phase out the use of ladder wells and cages.
From a best practices standpoint, we have never been fans of ladder cages because they don’t arrest falls. You can strike your head during a fall, lose consciousness, and create a extremely difficult rescue scenario for first responders. There are also cases of gruesome entanglements where falling workers tear off body parts during a rapid, uncontrolled descent.
The revised ruling establishes a phase out of ladder wells and cages over the next 20 years per OSHA 1910.128(b)(9)(i). Here are the implementation details:
- For caged, fixed ladders erected before November 19, 2018, employers have up to 20 years to install ladder safety or personal fall arrest systems (1910.28(b)(9)(i)(A))
- For new fixed ladders erected on or after November 19,2018, the employer must equip the ladder with a ladder safety or personal fall arrest system (1910.28(b)(9)(i)(B))
- For ladder repairs and replacements, when an employer replaces any portion of a fixed ladder, the replacement must be equipped with a ladder safety or personal fall arrest system (1910.28(b)(9)(i)(C))
- After November 18, 2036 all fixed ladders must be equipped with a ladder safety or personal fall arrest system (1910.28(b)(9)(i)(D))
Important Note: The revised ruling doesn’t require removal of ladder cages and wells prior to the final deadline (as long as their presence doesn’t interfere with the use of a ladder safety system or personal fall arrest system), but stipulates after the phase-out period, alternative forms of ladder fall protection are required to ensure compliance.
While we are on the subject of ladders, we should briefly mention billboard ladders. Prior to the revised ruling, employers in the outdoor advertising industry were exempt from OSHA’s 24′ fixed ladder threshold as long as their employees were certified as “qualified climbers.” Per 1910.28(b)(10)(i), OSHA specifies that the fall protection requirements for fixed ladders in final paragraph (b)(9) also apply to fixed ladders in outdoor advertising. Employers in this market sector have two years to install a cage, well, ladder safety system, or personal fall arrest system on unprotected ladders. During the two year phase-in period, employers must also ensure that each worker:
- 1910.28(b)(10)(ii)(A) receives training and demonstrates the physical capability to perform the necessary climbs in accordance with 1910.29(h);
- 1910.28(b)(10)(ii)(B) wears a body harness equipped with an 18 inch rest lanyard;
- 1910.28(b)(10)(ii)(C) keeps both hands free of tools and material while climbing the fixed ladder; and
- 1910.28(b)(10)(ii)(D) is protected by a fall protection system upon reaching the work position
Although the language above DOES reference the addition of a cage or well, we doubt many employers in the outdoor advertising industry will select these options since they are scheduled for phase-out in 2036.
We dedicated this post to a discussion of how the new OSHA regulations effect fixed ladder fall protection options, but the revised Walking-Working Surfaces Ruling is over 500 pages in length and covers a wide range of additional topics. If you are looking for a summary of the new fall protection regulations, we suggest downloading our e-book on this subject, or contact the safety professionals at Diversified Fall Protection for further assistance.