Recently, we’ve seen much confusion over the fixed access ladder heights, and when fall protection is required. For example, we recently fielded an e-mail inquiry asking if a 50 foot ladder consisting of 10 foot sections requires fall protection. We’ve also had clients ask if fall protection is needed on a 20 foot ladder that starts 10 feet off the ground. If you are confused by when your fixed access ladder needs some form of fall protection, we have just the post for you…..
Total Fall Distance is Key
The short answer to the questions posed above depends on the distance a worker on the ladder could fall, not the length of any single section of the ladder. OSHA regulations require measurement of total fall distance above a lower level. Regardless of whether the ladder(s) are a continuous single straight climb, or include side-step-off platforms, you need to measure from the top of the ladder to the lowest level.
If the fixed ladder will reach more than twenty-four (24) feet above a lower level, you as the employer are required to incorporate a personal fall arrest or ladder safety system into the installation of the ladder. For reference, this requirement is cited in OSHA Section 1910.28(b)(9)(i).
In another installation scenario, a multiple section or side-step ladder may be comprised of several sections each measuring less than 24 feet. If the total distance extends more than 24 feet above the ground, you must equip the entire ladder with personal fall arrest or ladder safety systems. Although the length of each section of the ladder may be less than 24 feet, a worker on that ladder could fall more than 24 feet.
OSHA also requires that if you make any adjustments, retrofits or extensions to a fixed access ladder currently considered compliant (see timetable below) you must ensure that a personal fall arrest or ladder safety system provide protection for the entire vertical distance of the ladder, including all ladder sections.
As a refresher, below is OSHA’s timeline for enforcement of OSHA regulations for ladders that extend more than 24 feet about the lower level, as well as the time table for phasing out cages and wells as a means of fall protection:
- For caged, fixed ladders installed 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 installed 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)). Please note–you won’t need to remove your cage after the final deadline, caged ladders will not be deemed OSHA compliant without an additional means of fall protection.
If you have questions about any requirements, applicability of devices or situational issues related to your ladders / your facility, give us a call. Our safety engineers will be glad to help.