Currently, under OSHA standard 1910.27 cages are required on ladders where the climbs are over 20 feet high. In OSHA’s new standard (OSHA standard 1910.28) taking effect 11/19/2018, a ladder will not be required to have fall protection until their height is over 24 feet (24’-0-1/4” requires fall protection).
OSHA will also be requiring ladders installed after 11/18/2018 to have fall protection in the form of a personal fall arrest system or ladder safety system (not a cage). If you have cages now, don’t worry, you will be grandfathered in for twenty years.
So, why the ladder change?
OSHA is aligning the fixed ladder standard to be more in line with the ANSI standard A14.3, which in 1979 changed its fall protection height requirement from 20’ to 24’.
Why are they telling us now when the ladder rule won’t go into effect until 11/19/2018?
OSHA wants to give the industry time to update products and procedures before they go fine crazy. You can now follow the new OSHA rule 1910.28 even though it is not in effect yet. You would not be meeting the current OSHA standard, but you would be in compliance with the future OSHA standard. OSHA would consider this a “de minimis violation”. De minimis violations are violations of standards which have no direct or immediate relationship to safety or health, and do not result in a citation, or penalty and need not be abated.
So, what does this all mean to you and what do you need to be aware of when dealing with all fixed ladders 24’ or more? According to OSHA the following actions need to take place:
1. Installing personal fall arrest or ladder safety systems on new fixed ladders 24’ or more and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures starting November 19, 2018.
2. Ensure existing fixed ladders 24’ or more, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system by November 19, 2018, and
3. Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders 24’ or more by November 18, 2036.
Where do you go from here and what personal fall arrest system will work on a ladder?
Today’s manufacturers of fall protection have created several fixed ladder fall arrest systems that are easy to install and cost much less than the traditional cages and wells of the past. It’s important to also make sure that all personnel who use a personal fall arrest system, even on fixed ladders, are properly trained and all equipment is inspected in accordance with the OSHA fall protection standard.
Written by Mike Kay,
Resource Safety Services, a division of Safety Products Inc