Walking Working Surfaces Standard Update: Fixed Ladder Use

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Article originally published Nov. 20, 2017, and updated for accuracy and relevance.

While most elements of ladder safety might seem like common sense, OSHA requires that employers take additional measures to ensure that their workers’ safety isn’t compromised. Of several topics covered in the most recent Walking Working Surfaces standard, updates detailing fixed ladder use within general industry settings were a key focus.

Here are changes made to the ladder safety specifics of OSHA’s Walking Working Surfaces standard in 2017. Learn what’s needed for fixed ladder compliance and the deadline for doing so.

How OSHA’s Standard Update Impacts Fixed Ladders

The standard defines a fixed ladder as any ladder over 24 feet, with rails or individual rungs, that is permanently attached to a structure, building or equipment. An individual-rung ladder is one example of a fixed ladder. Ship stairs, step bolts and manhole steps are exceptions to that classification.

The existing OSHA rule requires that employers have cages/wells installed on all fixed ladders, but allows up to two years for fixtures to be brought to standard. The old standard required fixed ladders greater than 20 feet above the lower level to have a cage or well, but the update has expanded that requirement to ladders greater than 24 feet. This brings the standard for general industry in-line with OSHA’s current standards for construction ladders.

Challenges with Existing Cage Systems

By design, cages and wells were intended to help workers fight fatigue by providing them with a place to rest while climbing (allowing them to lean back against the structure). Another thought was that workers could “catch” themselves on the cage if they happened to slip from the ladder. In practice, many workers have actually sustained greater injury when falling due to collision with the cage structure on the way down.

To help employers plan for the upgrades and adjustments necessary to make their fixed ladders safer, OSHA has established a 20-year schedule accounting for time to phase in ladder safety and personal fall arrest systems while phasing out existing cages.

The timelines associated with this schedule are detailed in the Walking Working Surfaces standard and vary depending on the required updates:

Existing Fixed Ladders
For all ladders erected before Nov. 19, 2018, employers have until Nov. 18, 2036 to install ladder safety or personal fall arrest systems. OSHA requires employers to equip existing ladders with at least one of the following devices by the deadline:

• A cage/well
• A ladder safety system
• A personal fall arrest system

New Fixed Ladders
All ladders erected on or after Nov. 19, 2018 must be equipped with a ladder safety or personal fall arrest system. Cages or wells alone are no longer considered compliant for new fixed ladders.

Ladder Repairs and Replacements
When an employer replaces any portion of a fixed ladder, the replacement must be equipped with a new ladder safety or personal fall arrest system.

Conney-Blog-Fixed-Ladder-2.jpgFixed Ladder with a Cage System

Other Safety System Considerations

A non-custom ladder safety system is typically made up of either a cable or track system running the length of the ladder. This allows a worker to attach to either a “cable-grab” or “track-grab” fall arrester from a full-body harness. While cable systems are generally considered easier to install and more cost effective, some argue that the track-type systems last longer.

The old Walking Working Surfaces standard for general industry required landing platforms on fixed ladders in 30-foot intervals. After the Nov. 19, 2036 deadline, OSHA’s standard will require rest platforms every 150 feet when coupled with a personal fall arrest or ladder safety system, consistent with OSHA’s construction industry standards. In circumstances where workers must still rely on cages, landing platforms at 50-foot maximum intervals must be provided. This is an important distinction.  

Applying This Standard Across Industries

The standard tries to consider circumstantial variations from one industry to the next. For example, a separate discussion in the standard’s preamble, and in the final standard, addresses ladder usage specific to outdoor advertising. The primary change from the old standard is that outdoor advertising employers must now also comply with the 24-foot fixed ladder rule and provide fall protection for their employees once they’ve reached the working position.

Regardless of the specific industry, the best option for employers who are striving to maintain the safest possible work environment would simply be to install safety systems on any ladder over 24 feet in length. In fact, some proactive companies take extra precaution, installing such systems on fixed ladders as short as 10 feet. The process to upgrade for these devices is quite easy and rarely involves a subcontractor for installation.

Note: OSHA does not require existing cages to be removed once alternative ladder safety or personal fall arrest systems are installed. 

When the standard was finalized, OSHA presumed that employers were already compliant with current standards, meaning that existing fixed ladders had been equipped with cages or wells. However, records indicate that some employers had still not complied with that old requirement at the time the standard was issued. As a result, employers essentially have a “free pass” through the Nov. 19, 2018 deadline to implement one of the above safety devices.

Although they could legally do so, employers are unlikely to install a new cage or well system on an existing fixed ladder. When compared to ladder safety or personal fall protection systems, cages and wells are proven to be less safe and are estimated to cost as much as three times more to install.

Make Safety Your Priority

As industry continues to evolve to meet consumer demands, the industrial working environment changes along with it – often times presenting new, hazardous conditions. OSHA plays a vital role in evaluating and course-correcting their standards in order to stay in front of these new risks. Now that we’ve detailed some of the ladder safety specifics in OSHA’s Walking Working Surfaces standard, you can evaluate.

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