OSHA Fall Protection Requirements
Note: This article has been updated to reflect changes to OSHA’s Walking/Working Fall Protection Standard related to fixed ladders.
On October 16, 2003 we posed the question, “Is a cage ladder really a safe form of fall protection?” Commonly seen on work platforms, silos and tall buildings either fully caged or the uppermost portion caged and often broken into sections with a landing platform at each section.
The previous OSHA Standard
At one time OSHA 1910.27, stated fixed ladders higher than 20’ but less than 30’ must include a cage. It went on to state that ladders over 30’ in length were required to also have a landing platform for each 30’ in height. Landing platforms serve to provide a resting spot for the climber. Theoretically the cages are built to provide fall protection for the climber in case he slips while climbing. However, Flexible Lifeline Systems has always felt a caged ladder provides more psychological protection than actual fall protection.
Common Errors Made By End Users
Unfortunately, there have been cases of caged ladders being misused and actually contributing to falls. One of the most common unsafe practices is for a climber to lean back against the cage to free up a hand and allow them to hold tools while climbing down. This technique is the reason ladder cages are often referred as “back scratchers”. During one occasion, a worker who was unaware of his exact location on the ladder attempted to lean back against the cage. He misgauged his position and attempted to lean at the bottom of the ladder where the cage no longer existed (cages end 7’-8’ from the ground or platform). As a result, the worker fell over the railing of the landing platform and suffered fatal injuries.
The Reality of Cage Ladders
Even without misuse, how much fall protection does a caged ladder really provide? Not a lot. In the time it takes a human to react to falling, they will have fallen several feet. Assuming the climber has the sense to stick his arms and legs out to catch him, he is still likely to endure severe injuries and broken bones. Therefore, it is safe to assume that cages on ladders do not provide a positive and predictable method of fall protection. Keep on the lookout as we will follow up this blog with a discussion on the integration of cage ladders and fall arrest systems. You might be surprised to hear what we have to say.
What Has Changed to the OSHA Standard?
The short story is this…cages are being phased out. OSHA’s Final Rule in its General Industry Walking-Working Surfaces and Fall Protection Standards was released on January 2017 (roughly 4 years after the original publishing of this article).
The rule applies to Fixed Ladders permanently attached to a structure, building, or equipment including individual-rung ladders, but not ship stairs, step bolts, or manhole steps. The new rule phases in a requirement for employers to have ladder safety or personal fall arrest systems for fixed ladders that extend more than 24 feet, and phases out the use of cages or wells for fall protection according to the following timeline:
- New height requirement. Fall protection is required on ladders taller than (or that extend beyond) 24 feet.
- New equipment specification. As of November 19th, 2018, cages are no longer considered compliant fall protection in newly installed ladders. To meet OSHA standards, a personal fall arrest system or a ladder safety system is required.
- Repair/replacement specification. As of November 18th, 2018, a personal fall arrest system or ladder safety system will be used to replace any damaged or nonfunctioning section, cage or well previously installed on a fixed ladder.
- OSHA is giving general industry a heads up and deadline. As of November 19th 2036, cages will no longer be accepted as a form of fall protection, and all fixed ladders taller than (or that extend beyond) 24 feet high must use a personal fall arrest system or a ladder safety system.
How to ensure compliance
Even though cages and wells were accepted at one time, our team has never viewed them as an adequate form of fall protection. We’ve had decades of experience in providing safe and complaint solutions for fixed ladder users. Contact one of our Fall Protection Specialists to perform a safety audit.