When Will a Personal Fall Arrest System or Ladder Safety System be Required on a Fixed Ladder?

Falls from elevated work surfaces, including ladders, are a leading cause of serious injuries and fatalities in the workplace. To combat this, the Occupational Safety and Health Administration (OSHA) has stringent regulations regarding fall protection on fixed ladders. Understanding these standards is crucial for employers to ensure worker safety and maintain compliance. If you're wondering if your fixed ladder is OSHA compliant, this article is for you.

The 24-Foot Threshold and Phased Compliance

The primary trigger for requiring a Personal Fall Arrest System (PFAS) or Ladder Safety System on a fixed ladder is when the total length of the climb equals or exceeds 24 feet (7.3 meters). This requirement is outlined in OSHA standard 29 CFR 1926.1053(a)(19) for construction and 29 CFR 1910.28(b)(9) for general industry.

It's important to note that OSHA has implemented a phased approach for compliance, particularly concerning older fixed ladders that may have been equipped with cages or wells. Here's a breakdown:

• Fixed ladders installed on or after November 19, 2018: These ladders, if exceeding 24 feet, must be equipped with a PFAS or ladder safety system. Cages and wells are no longer considered compliant fall protection for newly installed ladders.
• Existing fixed ladders (installed before November 19, 2018): These ladders, if over 24 feet, could originally use a cage or well as fall protection. However, OSHA mandates that by November 18, 2036, all fixed ladders exceeding 24 feet must be equipped with a PFAS or ladder safety system, effectively phasing out cages and wells as standalone fall protection.
• Replacement or modification of existing ladders: If a fixed ladder, cage, or well (or any portion thereof) is replaced or modified after November 19, 2018, the replaced or modified section must be brought into compliance with a PFAS or ladder safety system, even if the entire ladder is not yet due for upgrade by the 2036 deadline.

Why Not Continue to Use Ladder Cages?

Historically, cages were a common form of fall protection on fixed ladders. However, research and incidents have demonstrated that cages often provide a false sense of security and are largely ineffective in preventing serious injuries during a fall. In some cases, they can even cause injury by trapping or entangling a falling worker. OSHA's updated standards reflect a shift towards more active and effective fall protection solutions.

Understanding Personal Fall Arrest Systems (PFAS)

A Personal Fall Arrest System (PFAS) is designed to safely stop an employee's fall from a working level. A complete PFAS consists of three main components, often referred to as the "ABC" of fall protection:

• A - Anchorage: A secure point of attachment for the fall arrest system. For fixed ladders, this could be a structural component of the ladder or the building designed to withstand the forces of a fall. OSHA generally requires anchor points to support at least 5,000 pounds per employee attached, or be designed and installed under the supervision of a qualified person.
• B - Bodywear: This is almost exclusively a full-body harness. The harness distributes the impact of a fall across the worker's body, minimizing injury. (Note: Safety belts (waist belts) are no longer permitted for use as PFAS equipment in construction and general industries.)
• C - Connecting Device: This links the body harness to the anchorage. Examples include:
  • Lanyards: Typically 6 feet in length, often incorporating a shock absorber to reduce the force of the fall.
  • Self-Retracting Lifelines (SRLs): These devices function similarly to a car seatbelt, extending and retracting with the worker's movement and locking quickly in the event of a fall, limiting the fall distance.

Understanding Ladder Safety Systems

A Ladder Safety System is a type of fall protection specifically designed for fixed ladders. These systems generally consist of:

• A carrier: This is a flexible cable or rigid track that runs the entire vertical length of the fixed ladder.
• A safety sleeve (or trolley/rope grab): This device attaches to the worker's full-body harness and connects to the carrier. As the worker ascends or descends, the safety sleeve moves with them. In the event of a fall, the sleeve automatically locks onto the carrier, arresting the fall.
• Connecting components: These include a lanyard and connectors to link the safety sleeve to the harness.
• A fixed anchor with a connected mechanical fall arrest device (SRL).

Examples of ladder safety systems include vertical cable lifeline systems, rigid rail systems, and ladder stanchions that attach to the top of the ladder and provide protection through attachment of a self retracting lifeline accessed by a tagline. All of these systems allow for continuous fall protection as the worker climbs, offering a significant safety improvement over traditional cages. Most importantly, all of these are simple, safe alternatives to ladder cages that ensure long term OSHA compliance.

In Conclusion

The evolution of OSHA's standards for fixed ladders underscores a strong commitment to worker safety. While older caged ladders have a grace period, the clear direction is towards more effective fall protection through Personal Fall Arrest Systems and Ladder Safety Systems for all fixed ladders exceeding 24 feet. Proactive compliance not only ensures adherence to regulations but, most importantly, protects lives and prevents serious injuries in the workplace.

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goSafe offers a variety of Ladder Safety Systems designed to ensure the safety of anyone climbing a fixed ladder. Ladder Stanchion Systems are available in multiple materials and configurations, as standalone stanchions or as complete systems including an SRL. Ladder Davits with a Mechanical Lift make traversing fixed ladders through a ceiling hatch safe and easy. For more information on these systems and other Fall Protection equipment from Reliance, contact us at sales@gosafe.com

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