Photo courtesy of Diversified Fall Protection

OSHA Updates to Fixed Ladder Fall Protection Requirements   

By Philip Jacklin

OSHA 1910 Design Standard for Ladders
    Upgrading existing ladders with equipment to comply with new fall protection mandates should be a priority for employers, but they must confirm adherence to OSHA’s ladder design specifications as well. If retrofitting must occur, it is likely to be more cost-effective for building owners to perform all necessary improvements at the same time. In this author’s opinion, there is no partial compliance with OSHA; effective safety managers should view compliance with OSHA as all or nothing, 0% or 100%, etc. A non-compliant ladder with a ladder safety system could still cause avoidable injuries. OSHA’s minimum standard requirements may not be comprehensive, but they aim to guide employers in providing a safe work environment for their employees.

Image B Courtesy of Diversified Fall Protection

Figure C Courtesy of Diversified Fall Protection

    OSHA’s design specifications can help decrease the risk of a worker falling while climbing fixed ladders — see Figure A. For example, ladders must be a minimum of 7 inches away from the mounting structure when measured to the centerline of the rungs to accommodate the worker’s foot securely being placed on the ladder rung. Feet can more easily slip off ladder rungs if only the toes or ball of the foot can step on the rung. Additionally, ladder rungs can range from 10 inches — 14 inches but must be uniformly spaced for the length of the ladder. Ladders must be a minimum of 16 inches wide.
    Building owners must also ensure a minimum 30-inch clearance surrounding the climbing side to maintain an unobstructed climbing path for the worker. Historically, this was accomplished by adding a ladder cage — see Image B. Furthermore, fixed ladders must extend at least 42 inches above the landing level, with the side rails being spaced between 24 inches — 30 inches apart. This design provides the worker with a safer means to access the landing level and return to the ladder for descent — see Figure C.
    While it might be stating the obvious, building owners & employers greatly benefit from providing the safest means possible to access their rooftops or other elevated locations. Adhering to the above design requirements will not only avoid citations from OSHA but can also help decrease the possibility of accidental falls on a fixed ladder in the facility.

Fall Protection Updates for Fixed Ladders
    Effective November 2018, all permanent, fixed ladders over 24 feet now require a personal fall protection system (or ladder safety system) to be installed. This pertains to any permanent, fixed ladder that exposes a worker to a fall hazard of 24 feet or greater, regardless of the ladder’s material length or location in the facility. If the worker can fall 24 feet or more at any point in climbing the ladder, that fixed ladder will be required to comply with this new standard. 
    If a ladder was installed in a facility before the November 18 effectiveness date, the building owner has until November 2036 to bring that ladder into compliance. However, retrofitting must occur before 2036 if an eligible ladder goes under any repair, maintenance, or construction. The building owner must install the fall protection equipment while performing the ladder's maintenance or repairs. It’s important to note that OSHA considers a newly-repaired ladder a “new” ladder, and since 2018 all “new” permanent, fixed ladders over 24 feet must be equipped with some form of fall protection. 
    Many employers decide to remove ladder cages while retrofitting their ladders into compliance, but that is not always necessary. Ladder cages can be helpful in keeping obstructions away from climbers or providing something to lean back on for support while climbing. However, we must acknowledge that they do not provide any means of fall protection and should not be considered as such. Their removal is only required if the cage prohibits or impedes the installation or functioning of a ladder safety system.

Fall Protection Options for Fixed Ladders
    Unfortunately, while OSHA’s mandate is clear on establishing requirements and a timeline to meet them, it is less clear on what solutions will meet compliance and keep workers safe. There are essentially three equipment options that can be utilized with new ladders or retrofitted onto existing ones: ladder safety systems, ladder anchors, or tripods. 

Ladder Safety Systems
    Many companies offer ladder safety systems to meet the new fixed ladder fall protection requirements. These systems are comprised of a cable or rail system that extends the entire ladder height and requires attachment brackets at the top and bottom of the ladder. Both have a “shuttle” device that connects to the user’s chest D-Ring on their fall protection harness, which must maintain a straight angle to allow for ascending or descending. This mechanism acts as a fall-arresting device because if a worker is to fall and the angle of the shuttle to the cable/rail becomes too great, the shuttle locks up and immediately restricts any movement. 
    The differences between cable and rail systems are minimal but important to know. They function almost identically in terms of protecting a ladder climber from a fall. However, cable systems will have more flex since they are only attached at the top & bottom ends of the ladder — see Image D. This can sometimes allow for quicker & less expensive installation, but the flex on these systems sometimes proves more cumbersome for climbers and offers more challenges in maintaining the correct angle with t heir shuttle device. Often, workers must pause climbing to “pull” the shuttle up or down with them or experience the shuttle locking up when a fall hasn’t yet occurred. The shuttle’s sensitivity to lock up is generally a good thing for worker safety, but many workers can get frustrated with safety equipment that prevents them from carrying out their tasks normally. Frustrated workers are more likely to try to work without the safety equipment instead of modifying their work to accommodate the equipment. 

Image D Courtesy of Diversified Fall Protection

    Rail systems are mounted with intermediate brackets along the entire length of the ladder to provide a secure channel for the shuttle device as the climber ascends or descends the ladder. Since the system is more rigid than cable systems, the tension a worker creates by climbing is usually enough to pull the shuttle along with them. These systems are less likely to impede normal climbing behavior and simply provide fall-arresting capabilities if the worker loses consciousness or slips off the ladder at any point in the climb. 
    For both cable & rail systems, the user must don a fall protection harness that has a Chest D-Ring installed. Chest D-rings cannot be retrofitted onto harnesses; they must be pre-installed by the manufacturer. When adopting these systems into your facility, ensure current fall protection harnesses are compatible. Otherwise, purchasing new ones will be necessary. 

Ladder Anchors
    Ladder anchors attach to the top few rungs of a fixed ladder and contain an anchor point for use with a Self-Retracting Lifeline (SRL). An SRL of an appropriate length connects to the anchor point and has a tagline attached to the SRL’s snaphook. When a user is about to climb the ladder, they would pull the tagline down to their level and connect the SRL’s snaphook to the Dorsal D-Ring on their harness. They can then begin climbing the ladder, and the SRL can arrest their fall if they lose consciousness or slip off the ladder. Since the SRL is overhead, the brake will activate immediately once a fall occurs. 
    These systems are not as comprehensive as ladder safety systems, but they can be installed much quicker and can utilize existing equipment in the facility. Additionally, they negate the need to upgrade fall protection harnesses since SRLs can connect to a user’s Dorsal D-Ring — which every fall protection harness contains. However, standard SRLs cannot withstand constant outdoor exposure. If a fixed ladder is outside of a building, the employer would need to supply a “sealed” SRL to withstand the elements, and those units are often more expensive than ladder safety systems. Furthermore, SRL falls will generate more force and increase the risk of injury to the worker, as compared to falling with a ladder safety system’s shuttle device. 

Tripods
    Tripods are not feasible for most rooftop applications as they require a triangular shape around the ladder access location, but they are helpful for providing fall protection when climbing underground ladders. For example, a 24ft ladder from the street level down to a sewer cannot typically accommodate traditional ladder safety systems; the manhole cover would obstruct the top rung attachments. However, a tripod system can be temporarily set up above the manhole ladder and provide an SRL for a worker descending the ladder. Most tripod systems can be simultaneously equipped with a material winch to retrieve fallen/unconscious workers from underground ladder areas. Again, these systems should be used when they are the only feasible option in providing fall protection to ladder climbers, and permanent solutions should be used whenever possible. 

Conclusion
    It’s not often that OSHA updates can have a direct result in increasing worker safety. In this case, implementing these mandates as soon as possible can immediately lessen the risk presented by climbing your facility’s permanent, fixed ladders. Falls happen unexpectedly, or else they would be much easier to prevent. Upgrading to a ladder safety system gives workers a substantial piece of equipment that will protect them no matter what happens. 
    It’s also important to remember that OSHA minimum requirements are just that—minimum requirements. There is essentially no safe height to fall. Falls from any height can cause severe injury or worse. In fact, nearly 50% of fatal falls occurred below 20 feet, according to the Center for Construction Research & Training (CPWR). That is why it’s important not just to consider what ladders in your facility must be retrofitted to avoid future OSHA citations but also to consider that every ladder in your facility should be retrofitted with fall protection to protect workers at all times.
    When it comes to providing worker safety, OSHA regulations should be considered but not held as the goal. Aspiring to create a facility completely free of hazards or with every hazard effectively mitigated should be the ultimate goal. And for dedicated safety professionals, that might be a never-ending job, but it’s the most important one, especially for workers who deserve protection.