Understanding the New OSHA Regulations for Fixed Ladders

As of November 19,2018, the U.S. Department of Labor’s Occupational Health and Safety Administration (OSHA) implemented new requirements for fixed ladders on buildings. Understanding these new ladder regulations can be confusing, and you can spend a great deal of time referencing the standard interpretations pages on the OSHA website and still not find the answers you need. 

In this article, we will be referencing the OSHA fixed ladder rules found under Occupational Health and Safety Standards, Subpart D, Standard 1910.28, “Duty to Have Fall Protection and Falling Object Protection.” We will address some of the most frequently asked questions about the regulations for fixed ladders and include some tips and links to other resources for more information. 

What has OSHA changed?

The first and primary change is the phasing out of cages on fixed ladders. Many see this as a step forward for ladder safety. The reality is that cages offer little in the way of fall protection. In fact, they can increasethe risk of injury during a fall. 

Should we order our new ladder with a cage or not?

Under the new rules, cages are not required or recommended for any new ladder installation. We will get deeper into what this means for existing ladders later in this article.

The next question is if OSHA takes away cages, how are they planning to protect people from falls? This is accomplished using a personal fall arrest system (PFAS) or ladder safety system. These come in wide variety of designs. 

Three primary types are:

1. Bolt-on cable systems (with a cable grab fall arrester)

2. Track systems (with a climbing trolley)

3. Top-mounted self-retracting lifelines

Of course, each type has its advantages and disadvantages. The key is that each must meet the minimum OSHA requirements outlined in section 1926.502(d) of the OSHA codes. 

When is a PFAS Required?

Under the new regulations, a ladder over 24 feet high will require a personal fall arrest system or ladder safety system. You can choose any PFAS provided it meets the OSHA requirements in section 1926.502(d).

Please note: A ladder that is less than 24 feet high does not require a fall arrest system of any sort. 

What about landing platforms?

Multi-section ladders with a climb of 24 feet or more require rest points. These are meant to protect climbers as they ascend. Previously, a fixed ladder with a cage required a landing platform at a maximum interval of 30 feet.

The new regulations change this requirement dramatically. Fixed ladders without cages must now have a landing platform at maximum intervals of 150 feet. Ladders with cages must now have a landing platform at maximum intervals of 50 feet. 

How do the new rules affect existing ladders?

Under the new rules, the modification of an existing ladder or replacement of a ladder section requires that the modified or replaced section be equipped with a fall arrest system. 

By November 18, 2036, allladders 24 feet or higher must be retrofitted with a PFAS or ladder safety system.

Here’s the confusing part: Will all existing ladders with cages have to be replaced, or at least have the cages removed? No.The existing caged ladder can stay. But as outlined above, a fall arrest system of some type will have to be retrofitted. 

In such cases, the cage must not interfere with whatever fall arrest system is installed. Choosing the right type fall arrest is critical in these retrofit situations.

What questions should I ask then choosing a fall arrest system?

While the fall arrest systems themselves are not that complicated, the burden often falls on the purchaser to try to figure out all the parts and pieces needed to make their ladder OSHA compliant. 

It’s not uncommon to select a fall arrest system, only to find out the product or that the accessories needed to make it compliant might be discontinued or out of stock. This leads to a list of questions that you need to ask prior to picking a fall arrest system:

· Will this system work with my ladder and the height of my climb?

· What is the system’s load capacity? 

· Will the system allow for only one or for multiple climbers? How many?

· What is the true product cost? You need to gather information on the cost of not only the base components, but any accessories needed to make the system OSHA compliant, such as harnesses, cable grabs, trolleys, carabiners, etc. 

· Is the system, and all its accessories, readily available?

· Will replacement parts be available in the future?

Where can I turn for more information about ladder regulations? 

Reputable manufacturers and suppliers of ladders and fall protection equipment should have experienced personnel on hand that can help you navigate the new OSHA regulations. The OSHA website includes the regulations cited above, as well as a Q and A section that covers fixed ladders (https://www.osha.gov/walking-working-surfaces/faq.html). Contractors can also contact their area OSHA representative for assistance. 

Other OSHA ladder resources available online include:  https://www.osha.gov/stopfalls/trainingresources.html  and https://www.osha.gov/dcsp/alliances/alliance_products.html#Ladder.

The American Ladder Safety Institute also provides an online ladder safety training resource: https://www.laddersafetytraining.org/

About the author: Chris Lafferty is a sales and marketing associate with Design Components Inc., a full-service provider of fixed ladders and fall protection accessories. For more information, visit www.designcomponents.com

2012 Fatal Work Injuries Are Second Lowest Reported Since 1992

The final count of fatal work injuries in the United States in 2012 was 4,628, up from 4,383 preliminarily reported in August 2013. The final 2012 total was the second-lowest annual total recorded since the fatal injury census was first conducted in 1992. The overall fatal work injury rate for the United States in 2012 was 3.4 fatal injuries per 100,000 full-time equivalent (FTE) workers, down slightly from the final rate of 3.5 reported for 2011.

The final fatal work injury rate for 2012 is the lowest rate published by the program since the conversion to hours-based rates in 2006. The final 2012 numbers reflect updates to the 2012 Census of Fatal Occupational Injuries (CFOI) file made after the release of preliminary results in August 2013. Revisions and additions to the 2012 CFOI counts result from the identification of new cases and the revision of existing cases based on source documents received after the release of preliminary results. A table summarizing the results of the update process appears on the next page.

Among the changes resulting from the updates:

  • The total number of contractors fatally injured on the job in 2012 rose to 715 fatalities after updates were included. Contract workers accounted for over 15 percent of all fatal work injuries in 2012. For more information, see the
    table on contractor data.
  • Roadway incidents were higher by 109 cases (or 10 percent) from the preliminary count, increasing the total number of fatal work-related roadway incidents in 2012 to 1,153 cases. The final 2012 total represented a 5-percent increase over the final 2011 count.
  • The number of fatal work injuries involving Hispanic workers was higher by 40 fatalities after updates were added, bringing the total number of fatally injured Hispanic workers to 748. That total was about the same as the 2011 total (749), but the fatality rate for Hispanic workers declined to 3.7 per 100,000 FTE workers in 2012, down from 4.0 in 2011.
  • Work-related suicides increased by 24 cases to a total of 249 after updates were added. Workplace homicides were higher by 12 cases after the updates, raising the workplace homicide total in 2012 to 475 cases.
  • In the private transportation and warehousing sector, fatal injuries increased by 9 percent from the preliminary count, led by a net increase of 44 cases in the truck transportation sector.
  • A net increase of 31 fatal work injuries in the private construction sector led to a revised count of 806 for that sector. The 2012 total was an increase of 9 percent over the 2011 total and represented the first increase in fatal work injuries in private construction since 2006.

Overall, 36 states revised their counts upward as a result of the update process. CFOI has compiled an annual count of all fatal work injuries occurring in the U.S. since 1992 by using diverse data sources to identify, verify and profile fatal work injuries. For more information, see Chapter 9 of the BLS Handbook of Methods.

Fall-arrest System Includes Pneumatic Air Hose

USP Structural Connectors' MAX X-Line fall-arrest system

USP Structural Connectors’ MAX X-Line fall-arrest system

USP Structural Connectors has made its MAX X-Line fall-arrest system nationally available. The fall-arrest system reduces job-site tripping hazards by incorporating a pneumatic air hose within the fall-arrest system’s lifeline, allowing contractors to eliminate the unsafe presence of a pneumatic air hose in addition to a lifeline beneath their feet. The MAX X-Line lifeline also can be clipped into a USP permanent, gasketed anchor that can be attached to the structure’s framing.

(800) 328-5934