A structural engineer described an industrial tower with a fixed ladder that begins 100 feet above ground level. The base landing exists solely for ladder access, meets OSHA's minimum dimensions, and has standard guardrails. The climb length above the landing is under 24 feet. Does the ladder still need a personal fall arrest system (PFAS) or ladder safety system?
OSHA answered that the determining factor is the height the ladder extends above the ground/lower level and the distance a worker on the ladder could fall, not the length of a particular ladder or ladder section. Even though the climb section itself is under 24 feet, a worker could fall more than 24 feet total. For ladders installed on or after November 19, 2018, a personal fall arrest or ladder safety system must be installed (29 CFR 1910.28(b)(9)(i)).
On cages: they remain permissible only for existing fixed ladders erected before November 19, 2018, and only until replacement becomes necessary or November 19, 2036, whichever comes first. Cages are not permissible as a means of fall protection for new fixed ladders erected on or after November 19, 2018.