The new OSHA General Industry fall protection regulations that went into effect in 2017 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 an 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.
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 relating to ladders. 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.