Understanding the New OSHA Regulations for Fixed Ladders

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As of November 19,2018, the U.S. Department of Labor’s Occupational Health and Safety Administration (OSHA) implemented new requirements for fixed ladders on buildings. Understanding these new ladder regulations can be confusing, and you can spend a great deal of time referencing the standard interpretations pages on the OSHA website and still not find the answers you need. 

In this article, we will be referencing the OSHA fixed ladder rules found under Occupational Health and Safety Standards, Subpart D, Standard 1910.28, “Duty to Have Fall Protection and Falling Object Protection.” We will address some of the most frequently asked questions about the regulations for fixed ladders and include some tips and links to other resources for more information. 

What has OSHA changed?

The first and primary change is the phasing out of cages on fixed ladders. Many see this as a step forward for ladder safety. The reality is that cages offer little in the way of fall protection. In fact, they can increasethe risk of injury during a fall. 

Should we order our new ladder with a cage or not?

Under the new rules, cages are not required or recommended for any new ladder installation. We will get deeper into what this means for existing ladders later in this article.

The next question is if OSHA takes away cages, how are they planning to protect people from falls? This is accomplished using a personal fall arrest system (PFAS) or ladder safety system. These come in wide variety of designs. 

Three primary types are:

1. Bolt-on cable systems (with a cable grab fall arrester)

2. Track systems (with a climbing trolley)

3. Top-mounted self-retracting lifelines

Of course, each type has its advantages and disadvantages. The key is that each must meet the minimum OSHA requirements outlined in section 1926.502(d) of the OSHA codes. 

When is a PFAS Required?

Under the new regulations, a ladder over 24 feet high will require a personal fall arrest system or ladder safety system. You can choose any PFAS provided it meets the OSHA requirements in section 1926.502(d).

Please note: A ladder that is less than 24 feet high does not require a fall arrest system of any sort. 

What about landing platforms?

Multi-section ladders with a climb of 24 feet or more require rest points. These are meant to protect climbers as they ascend. Previously, a fixed ladder with a cage required a landing platform at a maximum interval of 30 feet.

The new regulations change this requirement dramatically. Fixed ladders without cages must now have a landing platform at maximum intervals of 150 feet. Ladders with cages must now have a landing platform at maximum intervals of 50 feet. 

How do the new rules affect existing ladders?

Under the new rules, the modification of an existing ladder or replacement of a ladder section requires that the modified or replaced section be equipped with a fall arrest system. 

By November 18, 2036, allladders 24 feet or higher must be retrofitted with a PFAS or ladder safety system.

Here’s the confusing part: Will all existing ladders with cages have to be replaced, or at least have the cages removed? No.The existing caged ladder can stay. But as outlined above, a fall arrest system of some type will have to be retrofitted. 

In such cases, the cage must not interfere with whatever fall arrest system is installed. Choosing the right type fall arrest is critical in these retrofit situations.

What questions should I ask then choosing a fall arrest system?

While the fall arrest systems themselves are not that complicated, the burden often falls on the purchaser to try to figure out all the parts and pieces needed to make their ladder OSHA compliant. 

It’s not uncommon to select a fall arrest system, only to find out the product or that the accessories needed to make it compliant might be discontinued or out of stock. This leads to a list of questions that you need to ask prior to picking a fall arrest system:

· Will this system work with my ladder and the height of my climb?

· What is the system’s load capacity? 

· Will the system allow for only one or for multiple climbers? How many?

· What is the true product cost? You need to gather information on the cost of not only the base components, but any accessories needed to make the system OSHA compliant, such as harnesses, cable grabs, trolleys, carabiners, etc. 

· Is the system, and all its accessories, readily available?

· Will replacement parts be available in the future?

Where can I turn for more information about ladder regulations? 

Reputable manufacturers and suppliers of ladders and fall protection equipment should have experienced personnel on hand that can help you navigate the new OSHA regulations. The OSHA website includes the regulations cited above, as well as a Q and A section that covers fixed ladders (https://www.osha.gov/walking-working-surfaces/faq.html). Contractors can also contact their area OSHA representative for assistance. 

Other OSHA ladder resources available online include:  https://www.osha.gov/stopfalls/trainingresources.html  and https://www.osha.gov/dcsp/alliances/alliance_products.html#Ladder.

The American Ladder Safety Institute also provides an online ladder safety training resource: https://www.laddersafetytraining.org/

About the author: Chris Lafferty is a sales and marketing associate with Design Components Inc., a full-service provider of fixed ladders and fall protection accessories. For more information, visit www.designcomponents.com

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