FAQs on new OSHA Fall Protection Regulations: Vol. 8 – Ladder Fall Protection II

Chains are no longer acceptable protection at ladder openings.

While our previous post in this series focused on the new requirement for ladder safety systems, this post discusses some additional requirements that affect ladder use and design. Here are a few of the most common questions we have received about ladders.

Are chains acceptable to protect ladder openings?

I often see chains at the top of fixed ladders, although when I see them, they are frequently hanging down. For access openings, only self-closing gates—not chains—were mentioned as acceptable for ladder openings in the new regulation. Obviously, chains will not meet the new self-closing requirement.

What are the requirements for self-closing gates?

OSHA1910.29 (b)(13) says that when guardrail systems are used around holes that serve as points of access (such as ladderways), the opening must have the following characteristics:

• Has a self-closing gate that slides or swings away from the hole, and is equipped with a top rail and midrail or equivalent intermediate member that meets the requirements
• As an alternative, you can offset the ladder opening to prevent an employee from walking or falling into the hole

What if I purchase a piece of equipment that already has a ladder integrally installed?

In OSHA 1910.23(a)(2), it specifically excludes ladders that are integral part of machines. However, it’s important to note that standard ladder requirements do apply if the ladder is attached to equipment, but not integral part of machines.

What are some general design changes that we need to incorporate now?

The changes highlighted in the table below showcase the required measurements that now apply to the design of fixed ladders. OSHA did not provide any time period for compliance on these changes, so technically these requirements apply to all fixed ladders used throughout your organization today.

Please subscribe or check back next Wednesday morning for the next installment in this blog series, which focuses on requirements related to guardrail. And, if you have your own specific questions, please comment below.