Are Your Fixed Ladders Compliant with New OSHA Regulations?

ladderFixed 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.



  1. Ladder safety is important. I am glad that OSHA has guidelines for businesses to follow. Thanks for sharing!

  2. What is the ladder is 20 feet?

    • Nolan Miller says:

      Ann, the new requirements state that the fall protection requirements are for ladders that “extend more than 24 feet above the lower level”. So two key points here is that the old 20 foot requirement no longer applies and secondly it is not the length of the ladder that is important, but the distance that a worker may fall to the “lower level” if they were to fall from the ladder.

      • What is the definition of the term “lower level”? Is it defined as the ground or is it the platform area immediately below the fixed ladder that the employee is climbing? For example, if I am climbing a fixed ladder that is positioned hallway up a 100 ft reactor tower, is the 24 foot potential fall threshold measured down to the ground level or to the platform level immediately below the fixed ladder itself?

      • Nolan Miller says:


        OSHA defines Lower Level as, “a surface or area to which an employee could fall. Such surfaces or areas include, but are not limited to, ground levels, floors, roofs, ramps, runways, excavations, pits, tanks, materials, water, equipment, and similar surfaces and structures, or portions thereof.”

        In your example you have to determine how far the worker could fall. If it is possible for the worker to fall all the way to the ground then that would be considered the lower level. Unfortunately this is an area where I believe there will have to be some judgment used to make that determination.

  3. hello, as I understand ladders will be substituted or replaced by fall arrest systems, at this moment 24’ is the mandatory distance to install the system, but we know that a person can die even on a fall of 10’ or less, does OSHA will require or suggest a safety measure for ladders between 10’ and 24’ ?

    • Raul,
      I apologize for the late response. OSHA does not, nor do I expect that they will require anything for ladders less than 24′. There are, however resources on the OSHA web site with suggestions for ladder safety regardless of the length. I would recommend that you take a look at these resources but if you have additional questions please reach out to me directly.

  4. i read the following ‘where the fall distance to the lower level exceeds 24 feet’. Does this lower level also apply to resting platforms? For example 2 caged ladder with an total height of 95ft (2 x 47.5ft with an small resting platform (6ft x 4ft) between the 2 caged ladders??

    • Nolan Miller says:


      OSHA defines the lower level as: “a surface or area to which an employee could fall. Such
      surfaces or areas include, but are not limited to, ground levels, floors, roofs, ramps, runways, excavations, pits, tanks, materials, water, equipment, and similar surfaces and structures, or
      portions thereof.”

      I believe that this would include the resting platform you describe but it could possibly be a lower level if there were a way for that employee to fall beyond that resting platform. In your example each ladder section exceeds the 24′ requirement and would therefore require a ladder safety or personal fall arrest system at some point in the future.

  5. Do the new regulations for fixed ladders on the outside of a building require a self closing gate at the point at the top of the ladder?

    • Gary, this is a question that has come up several times recently. I am trying to get a clarification from OSHA on this. In the meantime here are my thoughts:

      OSHA requires a swing gate when “guardrail systems are used around holes that are used as means of access (such as ladderways)” or have the guardrail opening “be offset to prevent an employee from walking or falling into the hole” However OSHA does not specifically address roof access points (as they do in 1926).

      If we apply the roof fall protection requirements then anytime we are less than 6′ from the roof edge we are required to be protected and this would apply at the ladder access point. This fall hazard would presumably addressed by guardrail on either side of the ladder, arranged such that an employee accessing the ladder can never be closer than 6′ to an unguarded edge. Therefore I would extrapolate that the ladder opening in that guardrail would require a swing gate.

      To me the key here is the unprotected roof edge. I believe that requirement is clearly defined. Anytime we approach the roof edge to access the ladder we must be protected once we are less than 6′ from the unguarded edge. That would likely mean guardrail, although the regulation allows for other options, and if we use guardrail then a swing gate would be required.

  6. UnderwoodGrandson says:

    Hey Nolan, thanks for the post. Very informative. After reading the post and the comments, I do have a question that I can’t seem to find an answer for. In your post, you say “…the primary focus of the new rule is to phase out cages as ‘fall protection’ on fixed ladders”. OSHA also states “Cages and wells are not ladder safety systems”. I understand this new rule applies to ladders that extend beyond 24′ and that OSHA does not have requirements for <24'; but does this mean we *cannot* (i.e. are forbidden to) use a Cage or Well on any ladders we design? What if we still _want_ to include a Cage or Well "for additional protection" (say, as a request from a client)? Thanks.

  7. Nolan Miller says:

    OSHA has stated that a cage can still be used. In cases where a ladder climbing system or personal fall arrest system is required, “1910.28(b)(9)(iv)
    The employer may use a cage or well in combination with a personal fall arrest system or ladder safety system provided that the cage or well does not interfere with the operation of the system. “

  8. Eric Wang says:

    What does a “Ladder Safety System” look like?


  1. […] (b)(9)(i)(B) specifically does not adopt the approach in ANSI/ASC A14.3-2008. As discussed in our previous blog on this topic, OSHA is pulling from evidence in the record that shows that cages and wells do not prevent workers […]

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