• Employees must be protected from falls while using fixed ladders that extend more than 24 feet above a lower level.
• Regulations vary depending on whether the fixed ladder was installed before or after November 19, 2018. If before, employers have until November 19, 2036 to bring their equipment up to the current standard.

The Occupational Safety and Health Administration (OSHA)’s fall protection requirement applies to fixed ladders that extend more than 24 feet above a lower level. This is found in 1910.28(b)(9). Employees are not required to use fall protection when working on portable ladders, nor when using fixed ladders under 24 feet.

OSHA determines the height of a fixed ladder based on the total distance between the starting level and the top level or the total potential falling distance, regardless of whether the climb consists of several sections. For example, if a climb consists of two offset ladder sections of 20 feet each, the ladder needs fall protection because the total height is more than 24 feet. Similarly, if employees access a 16-foot fixed ladder from a point 10 feet above a lower level (creating a potential fall of 26 feet), OSHA considers that ladder to be more than 24 feet.

For existing fixed ladders that extend more than 24 feet above a lower level and were erected before November 19, 2018, an employer has until November 18, 2036, to equip the fixed ladder with a ladder safety or personal fall arrest system. State plan states may allow additional time based on the date that they adopted the OSHA regulation.

A fixed ladder that extends more than 24 feet above a lower level and was erected after November 19, 2018 must be equipped with a ladder safety system or personal fall arrest system.

The employer may use a cage or well in combination with a personal fall arrest system or ladder safety system, provided that the cage or well does not interfere with the operation of the system.

Cages and wells must be designed, constructed, and maintained:

• To permit easy access to and egress from the ladder.
• To contain employees in the event of a fall.
• To direct employees to a lower landing.

The employer must ensure ladder sections having a cage or well:

• Are offset from adjacent sections; and
• Have landing platforms provided at maximum intervals of 50 feet.

If an employer repairs or replaces any portion of a fixed ladder that is more than 24 feet above a lower level, the replacement is required to be equipped with a ladder safety or personal fall arrest system. However, non-structural repairs such as replacing a bolt or repairing a weld on a cage do not require upgrading the ladder.