Are employees required to use personal fall protection on ladders?

Employees are neither required to use fall protection when working on portable ladders, nor when using fixed ladders at or under 24 feet. Rather, the duty to have fall protection applies to fixed ladders that extend more than 24 feet above a lower level. This is found in 1910.28(b)(9). The criteria for fall protection systems for fixed ladders is then found at 1910.29.

Note that OSHA determines the height of a fixed ladder based on the total distance between the starting level and the top level, regardless of whether the climb consists of several sections. For example, if a climb consists of two off-set ladder sections of 20 feet each, the ladder would need fall protection because the total height is more than 24 feet.

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

For existing fixed ladders that extend more than 24 feet above a lower level and are 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. (Note: on April 6, 2026, OSHA proposed to remove the 2036 deadline at 1910.28(b)(9)(i)(D). If finalized the change would allow upgrades to existing fixed ladders when they reach the end of their service lives.)

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.