![]() Question 4: If a fixed ladder goes up 20 feet to a platform and then goes to another fixed ladder that is an additional 20 feet, would that then count as a combined 40 foot fixed ladder and need a safety system? Additionally, 29 CFR § 1910.23(b)(13) requires that no employee carries any object or load that could cause the employee to lose balance and fall while climbing up or down the ladder. Response: Regardless of ladder height, 29 CFR § 1910.23(b)(12) requires that each employee use at least one hand to grasp the ladder when climbing up and down it. ![]() ![]() Question 3: Would simply maintaining 3 points of contact suffice for fixed ladders below 24 feet in height? However, if a ladder 24 feet or less in height is accessed from a platform at an elevated location and the employees can fall past the platform to a lower level, with a fall hazard greater than 24 feet, a cage can be used on that ladder to direct the employee to land on the platform and to limit the fall distance to 24 feet or less. Response: As stated in the response to question 1, fixed ladders that are 24 feet or less are not required to be equipped with a personal fall arrest system or ladder safety system, if the length of a fall to a lower level is 24 feet or less. Question 2: If a fixed ladder is 24 feet or less and requires a fall protection system, can a cage be used as a fall protection system? However, if a ladder 24 feet or less in height is accessed from a platform at an elevated location and the employees can fall past the platform to a lower level 1 with a fall hazard greater than 24 feet, the ladder must be equipped with a personal fall arrest system or ladder safety system. Response: Fixed ladders 24 feet or less in height above the ground level are not required to be equipped with personal fall arrest systems or ladder safety systems. If the fixed ladder is 24 feet or less, does a safety system (personal fall arrest system or ladder safety system) still need to be in place, as employers are still responsible to provide fall protection when employees are exposed to fall hazards of 4 feet or more? Question 1: 29 CFR § 1910.28(b)(9) requires fixed ladders (installed on or after November 19, 2018) that are more than 24 feet above the lower level, to be equipped with a personal fall arrest system or ladder safety system. Your paraphrased questions, and our responses are as follows: This letter constitutes OSHA’s interpretation only of the requirements herein, and may not be applicable to any questions not delineated in your original correspondence. Thank you for your letter to the Occupational Safety and Health Administration (OSHA), requesting clarification of the fall protection requirements for fixed ladders under OSHA’s Walking-Working Surfaces standard.
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