Plan your fixed ladder safety system upgrades

Employers with fixed ladders over 24 feet need to upgrade them with ladder safety systems or personal fall arrest systems by November of 2036, or sooner if the ladder is repaired. To meet that obligation, employers need to understand which ladders are covered and what type of repairs create an obligation to install those systems.

Covered ladders

The new fall protection requirements apply to ladders that reach more than 24 feet above a lower level. OSHA notes that the height includes all sections, as well as any vertical distance in between ladder sections (referred to as the “entire length of climb”). For example, a ladder with offset platforms might qualify as “more than 24 feet” even if individual sections are less than 24 feet.

Many ladders have cages or wells for fall protection. OSHA added a provision at 1910.28(b)(9)(iv) to clarify that employers do not have to remove cages or wells when installing a ladder safety system or personal fall arrest system, provided the cage or well does not interfere with the operation of that new system.

Minor repair vs. replacement

The regulation says that when a fixed ladder, cage, well, or portion of a ladder is replaced, then a personal fall arrest system or ladder safety system must be installed in the replaced portion. This does not require installing a ladder safety or fall arrest system on the entire fixed ladder if only one section needs replacement. The employer may upgrade only that section of the ladder, but leave the other sections for future upgrades.

OSHA does not require adding these safety systems when making minor repairs to ladders, cages, or wells. Examples include replacing a bolt or repairing a weld on a cage. However, when employers cannot simply make a repair but must replace that portion or section, the replacement must include a ladder safety or personal fall arrest system. Routine inspections required by 1910.22(d) should identify when a condition affects the structural integrity and necessitates replacement.

Although OSHA allowed 20 years for fixed ladder upgrades so employers could align the upgrades with routine maintenance or replacements. The first five years went by already. Employers still have 15 years to install the new systems, but should begin planning soon.