Will OSHA Remove the 2036 Ladder Deadline?

What the April 6, 2026 Proposal Means for Fixed Ladders Over 24 Feet.

On April 6, 2026 OSHA proposed removing the November 18, 2036 deadline in 29 CFR 1910.28(b)(9)(i)(D) for requiring all existing fixed ladders that extend more than 24 feet above a lower level to be equipped with a personal fall arrest system or ladder safety system. This article is going to look at the proposal in the context of current standards to illustrate what it means for facility managers, business owners, and employers. 

Why Is OSHA Reconsidering the Deadline Now?

OSHA’s purpose is to ensure that, wherever possible, every worker in the nation is safe and healthy while on the job. The Occupational Health & Safety Act of 1970 guarantees all Americans the right to a safe workplace. To accomplish this, OSHA sets standards they deem reasonably necessary or appropriate in order to keep workers safe. It is from this precedent that the 2016 updates to the Walking-Working Surfaces standards came into effect, as well as their 2036 deadline. 

On July 28, 2025 OSHA reported receiving a petition from member companies of American Fuel & Petrochemical Manufacturers (AFPM), American Chemistry Council (ACC), and American Petroleum Institute (API) to repeal the requirement for personal fall arrest systems on fixed ladders 24ft above a lower level. The petition claimed that the cost of retrofitting existing ladders was extraordinary and unjustified. 

It is fair to acknowledge that for large facilities with hundreds of ladders, the total sum of retrofitting can tally up quickly. However, ladder safety systems are generally considered among the less expensive systems in the fall protection industry for retrofitting. The average cost of a personal fall arrest ladder system is ~$2,500, and spreading out retrofit projects over the span of 20 years from 2016 to 2036 is much less of a financial burden than trying to complete them all in one go. This is why Diversified Fall Protection and other leaders in the safety industry have been advocating for large companies to begin working towards bringing their facilities into compliance sooner rather than later. 

By proposing to remove the 2036 deadline in paragraph (b)(9)(i)(D), OSHA is looking to allow employers more flexibility and less financial strain without compromising the updated standards in paragraph (b)(9)(i)(C). 

What Would Removing the 2036 Deadline Look Like?

It is important to note that this current OSHA proposal does not reconsider the updated fixed ladder requirements introduced in 2016: Ladders with a fall to a lower level of 24 feet or greater must be equipped with a safety system upon installation or maintenance. In other words, employers’ new deadlines are the service life of their ladders.  

The original 2036 deadline stemmed from the logic that the average useful life of fixed ladders, cages, and wells is 20 years and that by 2036, most of these ladders would be replaced or be in need of replacement at that time. Therefore, most ladders will trigger the requirement to add a personal fall arrest system before 2036, regardless of whether the deadline remains. 

So, what would removing the deadline do? For any fixed ladders over 24 feet that do not have a fall arrest system and do not need replacement before 2036, they would receive additional time to be brought into compliance. For companies already striving to exceed OSHA compliance and be proactive on worker safety, not much changes. 

Safety Vs. Compliance

OSHA’s recent proposal to remove the 2036 deadline is another reminder that achieving minimum regulation compliance does not necessarily make your fall protection program proactive or truly preventative. In recent years, many organizations have adopted the mindset of “exceeding” OSHA compliance and implementing fall protection & other safety equipment for the sake of protecting their workers in every way possible, whether or not there is a clear OSHA standard requiring the equipment. 

At Diversified Fall Protection, we believe that every workplace fall is preventable with the proper equipment & training given to employees. According to the National Safety Council (NSC), the majority of ladder deaths occur at heights of 10 feet or less. That data suggests there really is no “safe” height for a fall from a ladder and that even fixed ladders under 24 feet (for which OSHA does not require ladder safety systems) expose workers to life-threatening injuries.  

Furthermore, the direct costs of a workplace fall will almost always exceed the cost of installing fall protection equipment. That is why we work closely with our customer partners who have large facilities or numerous fall hazards to develop a plan to incrementally address their fall hazards and implement necessary equipment over time. We find that this better accommodates businesses with tight budgets and strict production schedules, without significantly impacting business operations. 

Our team of fall protection experts is experienced in accommodating business needs while staying focused on protecting workers. We believe that no worker should risk injury or fatality while working, and we can help your organization protect its workers so they can come back each day and help your company thrive.