OSHA Updates Regulations for Fixed and Portable Ladders

Update will require fixed ladders to have ladder safety or personal fall protection systems

by David Ivey

Malta, Ohio, July 8, 2019—New OSHA regulations pertaining to both fixed and portable ladders took effect on November 19, 2018, which may require some employers to update the safety systems they have in place for fixed ladders of 24 feet or taller. One of the headline changes is that ladder cages will no longer qualify as a safety system on fixed ladders of 24 feet and above, leading to a phasing out of ladder cages and wells in favor of ladder safety or personal fall protection systems.

Most of the rule took effect on November 19, 2018. A ladder safety or personal fall protection system is now required on all new fixed ladders of 24 feet or taller. In addition, any ladder repaired or replaced going forward must also be equipped with such a system.

Older ladders (installed before November 19, 2018) that are equipped with ladder cages or wells for fall protection will need to be equipped with a personal fall protection system or ladder safety system in order to be brought into compliance.

Examples of fall protection systems that can be used to ensure compliance include personal vertical lifelines, ladder-mounted cables, or a vertical track system.

Employers have until November 19, 2020, to bring their new ladders into compliance by installing personal fall arrest or ladder safety systems. They have 20 years to replace all cages and wells used as fall protection with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet. After November 18, 2036, all fixed ladders over 24 feet must be equipped with personal fall protection or ladder safety systems.

The updated rules gradually phase out ladder cages and wells that had previously been allowed as a form of fall protection for fixed ladders. Previously, the language of the OSHA rules allowed for the use of cages, wells, ladder safety devices, or self-retracting lifelines for fixed ladders above 24 feet. Although the new rules do not require the removal of ladder cages and wells, they do require an alternative form of fall protection, as these systems are no longer enough to ensure compliance under the revised rules.

Ladder cages have fallen out of favor as fall protection systems because they do not actively arrest an uncontrolled descent. A study by Safety Squared in 2004 for Health and Safety Executive (HSE)—the British government agency concerned with workplace health and safety regulations—found ladder cages to be unreliable at arresting downward falls.

Although ladder cages were intended to prevent workers from falling from ladders, there have been cases of misuse and unsafe practices that have instead contributed to falls. A commonly cited unsafe practice is for workers to lean against the cage (a practice that contributed to ladder cages earning the nickname “backscratcher.” There have also been cases of ladder cages creating entanglement with a falling worker as they try to catch themselves, resulting in serious injuries. In some cases, the physical barrier created by ladder cages can complicate rescue efforts.

The updated OSHA regulations reflect an industry consensus that modern fall protection systems, such as vertical lifeline systems, are considered far more reliable at arresting a downward fall. These systems are easy for workers to use and safely arrest falls automatically when used correctly.

The new rule also includes a training requirement for employers whose workers use fall protection or work in areas or situations where fall hazards exist. Employers must ensure workers are trained about fall and equipment hazards, including fall protection systems. They also must be retrained as necessary, such as when a change in operations or equipment occurs.

The changes to fixed ladder fall protection guidelines are part of a broader update to the revised Walking-Working Surfaces and Fall Protection Standards which covers additional topics related to walking-working surfaces in general industry. The rule is intended to incorporate modern industry best practices and consensus standards in worker protection related to slip, trip, and fall hazards and personal fall protection systems.

Falls from ladders account for about 20 percent of fatal and lost-time work injuries in general industry. OSHA estimates this rule will prevent 29 fatalities and 5,842 lost-workday injuries every year, according to the U.S. Department of Labor.

About the Author: David Ivey is a Fall Protection Engineer for Malta Dynamics, where he oversees the engineering and installation of all custom fall protection systems. For more information or with questions about OSHA compliance or fall protection systems, contact divey@maltadynamics.com.