Fixed ladders are among the many aspects of fall protection that are impacted by the recently published OSHA 1910 regulations. While the regulation went into effect on January 17, OSHA is allowing time to get your organization into compliance.
While some minor changes are required for clearances, rung spacing, step-across distance, and other ladder design elements, the primary focus of the new rule is to phase out cages as “fall protection” on fixed ladders. The fall protection industry has largely recognized that cages do not provide any type of protection from falling and can contribute to injury. With these new rules, OSHA codified the need to move away from the use of ladder cages as a means of fall protection while using fixed ladders.
“…ladder cages and wells may result in severe injury or fatality and increase the severity of fall injuries” (Commentary page 82602)
In lieu of using ladder cages, OSHA regulations now require the use of ladder safety systems (ladder climbing systems) or personal fall protection systems, such as a self-retracting device mounted above the ladder with a tag line to the bottom of the ladder.
“a ladder safety system is a system designed to eliminate or reduce the possibility of falling from a ladder. The final definition explains that a ladder safety system usually consists of a carrier; a safety sleeve, which is a moving component that travels on the carrier; a lanyard; connectors; and a body harness. The final definition also specifies that cages and wells are not ladder safety systems.” (OSHA 1910.21 (b))
Critical dates to be aware of:
- November 19, 2018 – all fixed ladders installed or replaced after this date (where the fall distance to the lower level exceeds 24 feet) must have a ladder safety system or personal fall protection installed as well regardless if a cage is installed.
- While the regulation allows for a cage to still be used as long as it does not interfere with the ladder safety system or the personal fall arrest system, I recommend eliminating the cage.
- November 18, 2036 – all fixed ladders regardless of installation date (where the fall distance to the lower level exceeds 24 feet) must have a ladder safety system or personal fall arrest system.
- As of November 19, 2018 these requirements apply to outdoor advertising activities as well.
One additional change to plan for is that fixed ladders equipped with ladder safety systems or personal fall protection systems must include rest platforms at intervals not to exceed 150 feet.
What can you do to prepare for these changes?
The number of fixed ladders currently in use by your organization will determine how you approach these required changes. In general I recommend that you take the following steps:
- Modify your design standards for fixed ladders to incorporate the new requirements that go into effect on November 19, 2018. This can be done immediately and can be implemented as soon as an approved design is in place.
- Develop an inventory of your current existing fixed ladders. This could be done as part of a broader fall hazard risk assessment or simply an assessment that focuses on fixed ladders within your site or organization.
- Develop a phasing plan that allows you to modify all ladders that requires a ladder safety system to meet the new requirements no later than November 18, 2036. Utilize what you know about the frequency of use for each ladder, future plans for that ladder, etc. to make valid decisions about the order in which to address each ladder.
- If possible, implement and execute this plan as soon as feasibly possible. There is no reason to wait until the deadline to reduce risk for workers exposed to these hazards.