Your commercial or industrial building's roof protects the structure, the contents, and the people who work there. It's also likely the location of your HVAC system, filtration, and other vital systems. Not only does your roof need regular maintenance and repairs, but so do your vital building systems. Providing rooftop fall protection such as guardrails, safety gates, and skylight guards help protect workers once they reach the roof. But in order to access the roof and the rooftop systems, workers, contractors, and inspectors will most likely have to climb a fixed ladder. In addition to your obligation to provide rooftop fall protection, you must also provide ladder fall protection.
Under OSHA 1910.28, you have a duty to provide fall protection when workers must perform their duties at a height of 4 feet or more above the previous level. Whenever anyone has to climb up to and access your commercial rooftop, it's your obligation to make sure that they are provided with adequate rooftop fall protection. You also need to provide adequate fall protection according to OSHA ladder safety guidelines.
If you do not comply with OSHA standards for fall protection on ladders, you can face steep fines and penalties. In addition, you're putting your most valuable assets – your employees – at risk. Rather than risk injuries, costly fines, as well as legal and financial consequences, responsible employers follow OSHA regulations implicitly.
But when it comes to fixed ladder safety and compliance, many questions may arise:
According to OSHA, a fixed ladder "means a ladder with rails or individual rungs that is permanently attached to a structure, building, or equipment. Fixed ladders include individual-rung ladders, but not ship stairs, step bolts, or manhole steps" (1910.21(b). Fixed ladders may be located on the building's exterior or inside the facility, for example, leading to a roof hatch.
According to OSHA 1910.28(b)(9), fall protection on ladders is required on any fixed ladder that extends more than 24 feet (7.3 m) above a lower level. The type of fall protection you are required to provide depends upon when the ladder was installed. There are distinct requirements for ladders installed before and those installed after November 2018. Check the records to verify the installation dates of any older ladders, and work with a safety expert to meet all OSHA requirements.
When a fixed ladder installed before November 2018 extends more than 24' above a lower level it should be equipped with a personal fall arrest system, ladder safety system, cage or well. You may use cages or wells for fixed ladders until the cage, well, or any ladder section requires replacement.
Per OSHA 1910.28 (b), you must ensure that every fixed ladder installed on and after November 19, 2018, is equipped with a personal fall arrest system or a ladder safety system. Note that the rules have changed and a ladder cage or well is no longer acceptable for fall protection purposes.
It is important to note that rooftop fall protection requirements for fixed ladders are not based on the overall length of the ladder. By contrast, the height the ladder extends above a lower level and the distance a worker on the ladder could fall, is used to determine the need for fall protection.
OSHA defines a personal fall arrest system as one that's capable of stopping an employee's fall from an elevated level. Generally, a personal fall arrest system consists of anchorage, connectors, and a body harness. In addition, a fall arrest system may include a lanyard, lifeline, deceleration device, or an appropriate combination of these devices.
OSHA defines a ladder safety system as a system that's designed to eliminate or reduce the possibility of falling from a ladder. Common components of a ladder safety system include a carrier, a safety sleeve, connectors, a lanyard, as well as a body harness.
Yes, you may install and use a ladder safety system with a cage or well. OSHA does require that the cage or well cannot interfere with the ladder safety system while it's in operation. When the ladder or a section of the ladder requires replacement, you will need to meet the post-2018 fall protection standards.
Eventually, you will have to completely replace fixed ladder wells and cages intended for fall protection. However, you have until November 2036 to complete the transition. If a fixed ladder, well, or cage needs to be replaced before that deadline, you'll need to meet the new standards for fall protection for fixed ladders.
Whether your fixed ladder is located inside your facility, leading to a roof opening, or attached to the outside of your building, the right equipment and expert advice can help make it safer. From OSHA-compliant ladder safety systems and personal fall arrest devices to guardrails and swing gates to protect ladder entrances, BlueWater are the industry leaders for OSHA ladder safety devices.
If you're attempting to update your indoor or roof fall protection or installing new systems, contact BlueWater to ensure you comply with the all standards pertaining to fall protection on ladders. Our team of safety experts will be happy to answer any fall protection questions you have about fixed ladders or any other hazard. We will also guide you through the process of determining the condition of your current ladder fall protection and the direction it needs to go to meet the most current OSHA guidelines.
