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24-Foot Rule for Mounted Access Ladders

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If you’ve been looking into OSHA’s revised Walking Working Surfaces Regulations or have heard about the November 19, 2018 implementation of new regulations for permanently mounted ladders, you may still be confused about the height requirements related to the “24-foot rule.”

Your safety engineer or maintenance crew may have questions like these:

“What if the ladder is made up of sections that are less than 24’…do I need fall protection?”

“What if the ladder is only 20′ long, but starts 10′ above ground level?  What then?”

Whether an employer must equip a fixed ladder or ladder sections with fall protection depends on the distance a worker on the ladder could fall, not the length of any single section of the ladder.

Total Fall Distance is Key

OSHA regulations require measurement of total fall distance above a lower level to follow “24-foot rule”. 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 the “24-foot rule”:

  • Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures (November 19, 2018).
  • Ensuring existing fixed ladders over 24 feet, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system (November 19, 2018).
  • Removing and replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet (November 18, 2036).

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.

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Did You Know?

In general Industry, any leading edge that is four feet or higher than the surface below must be protected from fall hazards?