Cages for Fixed Ladders Are No Longer Acceptable Fall Protection Under OSHA

Fixed ladders with cages have been a standard form of fall protection for many applications for a long time. However, a study conducted by Safety Squared in 2004 for the Health and Safety Executive in the UK found that fixed ladders with cages do not provide adequate fall protection to workers. In fact, many experts would argue that they offer no protection at all. Despite the 2004 study, OSHA code provided requirements for the safe implementation of fixed ladders with cages until a change in 2016.

OSHA rolled out new requirements in 2016 to reflect the changing understanding of and attitude toward the safety of fixed ladder cages. These changes are based on research, including the Safety Squared report and other studies, that has demonstrated that fixed ladder cages do not offer adequate protection from falls. This research on fixed ladder cage effectiveness prompted OSHA to update its fixed ladder requirements to improve protection from falls at height, provide greater flexibility to employers, and make compliance easier and less costly.

OSHA Fixed Ladder Cages Regulations

Many governing institutions and industry standards organizations have specified ladder cage regulations in the past, including both OSHA (1910.21-1996) and ANSI (A14.3-2008), as well as international organizations. The 2004 Safety Squared report explored some of these requirements, which offers some insight into why OSHA has chosen to eliminate fixed ladder cages.

In 1996, OSHA 1910.21 defined a cage as “an enclosure that is fastened to the side rails of the fixed ladder or to the structure to encircle the climbing space of the ladder for the safety of the person who must climb the ladder.” It defined a ladder safety system as a device, other than a cage or well, designed to eliminate or reduce the possibility of falling from a ladder.

These different definitions show the way both safety devices were viewed at the time those OSHA fixed ladder guidelines were implemented. While ladder safety devices were specifically intended to arrest or prevent falls, cages were intended to improve safety, but without any specific explanation of how they improve safety.

The same edition of OSHA 1910 provided requirements for landing platforms for fixed ladders. Under the code, any fixed ladder over 20 feet with a cage was required to have landing platforms every 30 feet, and any fixed ladder over 20 feet without a cage required landing platforms every 20 feet. However, any ladder over 20 feet that used a ladder safety device instead of a cage did not require landing platforms at all.

The different requirements for ladders with cages, without cages, and with ladder safety devices indicate that the purpose of the landing platforms is to stop a falling person. If they were intended for a different purpose, ladder safety devices—which are also designed to stop a fall—would also require landing platforms. 

Since ladders with and without cages require landing platforms at different increments, it is clear that fixed ladder cages were not believed to stop a falling person. Rather, these requirements suggest the platforms are intended to slow a falling person to be stopped by the landing platform.

OSHA Fall Arrest Requirements

With the 2016 update to OSHA 1910, the previous standards and requirements for fixed ladders with cages will be phased out in favor of ladder safety systems and personal fall arrest systems, or PFAS. OSHA 1910.28(b)(9) lays out the new requirements regarding both new and existing fixed ladders, PFAS and ladder safety systems, and compliance deadlines.

The new regulations, which went into effect on November 19, 2018, require specific protective measures for any fixed ladder that extends more than 24 feet above a lower level. Under this new regulation, any ladder installed before that date must have a PFAS, cage, ladder safety system, or well, and any ladder installed on or after that date must have a personal fall arrest system or a ladder safety system.

Note that this clause means that any fixed ladder installed on or after November 19, 2018, that uses a cage or well and does not have a ladder safety system or PFAS, will not comply with current OSHA requirements. Furthermore, if any fixed ladder, cage, or well is replaced after that date, a ladder safety system or PFAS must be installed to remain compliant (1910.28(b)(9)(i)(C)). 

Finally, November 18, 2036 is the deadline for all existing fixed ladders to be brought into compliance with the new OSHA regulations. On this date, all fixed ladders must have an attached PFAS or ladder safety system. OSHA will consider any fixed ladder using only a well or cage to be non-compliant. However, existing cages or wells can remain as long as they don’t interfere with the required safety system.

The new changes in these regulations also come with new requirements for landing platforms. Any fixed ladder that requires a PFAS or ladder safety system must also have rest platforms at intervals of no more than 150 feet. Additionally, any ladder section that includes a cage must be offset from other section and have landing platforms no less than 50 feet apart. Note that these sections still require a PFAS or ladder safety system.

These new regulations are aimed at enhancing protection from falls and preventing injury during a fall. Whether your ladder is new or has been in place for a few years, it’s important to make the necessary modifications or replacements to stay OSHA-compliant. 

OSHA Update

Falls from height and falls on the same level are among the leading causes of serious work-related injuries and deaths. This change to OSHA 1910 is intended to better protect workers in general industry applications from fall hazards than the previous standards did. The rule incorporates modern safety technology and consensus standards to bring OSHA codes in line with improved workplace safety information and practices.

In addition to prohibiting ladder cages and wells as primary safety methods, the rule also eliminates the requirement to use guardrails as primary fall protection. This elimination gives employers more flexibility to use the systems they believe will work best for a given situation. It also removes exceptions for the outdoor advertising industry and includes new training requirements for workers who use fixed ladders. These changes align fall protection requirements for general industry with those for construction as much as possible.

The Safety Squared study from 2004 and other studies have demonstrated that fixed ladder cages fail to provide real fall protection benefits. By incorporating new standards and updating OSHA general industry regulations to no longer consider cages sufficient fall protection, OSHA estimates this rule will prevent dozens of fatalities and over 5,000 lost-workday injuries every year.

At Rigid Lifelines, we offer Fall Protection Systems that can help keep your employees safe and your business compliant. Our Anchor Track® Active and Passive systems attach to your workers directly or protect them from falling. These systems give your workers the flexibility they need to move around and do their jobs while preventing impact if they lose their balance. 

In addition, we also offer systems that you can use for fall restraint and fall arrest, such as our Rigid Rail Enclosed Track, which stops falls as early as possible. Visit our website to see all of our fall protection systems that meet OSHA and ANSI fall protection codes.