STI/SPFA Guidance Document on Ladder Cages

On January 17, 2017, most of OSHA’s final rule to update the General Industry 1910 Subpart “D” Walking-Working Surfaces became effective.  Employers should review this update in its entirety to ensure compliance with the standard.   The purpose of this letter will focus specifically on 1910.28 “Duty to have fall protection and falling object protection,” and the updated requirements pertaining to fall protection requirements on fixed ladders, found in 1910.28(b)(9) – 1910.28(b)(9)(i)(D).   Note – this section of the standard has delayed effective dates and conditions, including:

• Installing personal fall arrest or ladder safety systems on newfixed ladders over 24 feet (20 ft or taller in California) – and on replacement ladders/ladder sections (November 19, 2018),
• Ensuring existing fixed ladders over 24 feet (20 ft or taller in California)- are equipped with a cage, well, personal fall arrest system, or ladder safety system (November 19, 2018),
• When a fixed ladder, cage, or well, or any portion of a section thereof, is replaced, a personal fall arrest system or ladder safety system is installed in at least that section of the fixed ladder, cage, or well where the replacement is located, and
• Replacing cages and wells(used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet (20 ft or taller in California)- (November 18, 2036)

As referenced above, one of the most significant changes to the standard is focused on fall protection requirements while ascending and descending fixed ladders.  According to the published Federal Register, OSHA is phasing out the use of cages and wells as a means of fall protection.  OSHA acknowledges there is wide recognition in the industry that cages and wells neither prevent workers from falling off ladders, nor protect them from injury when a fall occurs.  Moreover, as cited in OSHA’s final rule from the research report titled “Preliminary investigation into the fall-arresting effectiveness of ladder safety hoops”:

After studying the information from the references, the survey from the accident database and the results from testing, it seems clear that caged ladders cannot provide positive fall-arrest capability, especially in the case of the three-upright design which was tested as part of this research. There is every possibility of a fall downward inside of the cage to the ground or other platform below. There would appear, or so it seems, a possibility to stop the fall of a worker in certain circumstances, but this depends upon the attitude of the worker both before the fall and during the fall, and whether or not the worker manages to catch part of his or her body in one of the cage apertures, or manages to trap themselves in the cage some other way. In any event, it is a chance occurrence, and the opinion is that even if the worker could be caught by the cage, it could lead to significant if not fatal injury.

If a worker falls from a fixed ladder, a cage will only direct the falling worker to a lower landing rather than prevent the worker from falling and striking a lower landing.

Alternatively, a personal fall arrest system or ladder safety device alone will stop a worker from falling.  Workers who fall while properly connected to a personal fall arrest system or ladder safety devices are more capable to self-rescue, with the ladder directly in front of them.  When a cage is utilized, employees that fall even short distances, may have the potential for injury and trauma from striking the cage or well components during the fall.

Furthermore, a cage increases the risk of serious injury or death due to cage entanglement with the falling worker.  Rescuing an injured worker that has become entangled with a cage requires specialized training, equipment, and precious time to complete a complex and risky high-angle rescue under the worst of conditions thereby exposing additional workers to the risk of a fall or other injurie.  The presence of a cage will change a relatively simple rescue off of a platform or roof into an extremely difficult rescue that requires the navigation of each cage. Likewise, using a spine board, stokes basket, or performing a companion rescue (two-person rescue that allows EMS to monitor the victim) is nearly impossible when a cage is involved.  Additionally, OSHA’s final rule states:

“The accidents reviewed indicate that workers fall down cages to the next level and are rarely caught. Injuries have been reported. Even if a fall is halted by limb entanglement within a cage, rescue would be extremely difficult process to carry out successfully (Ex. 392).”

As illustrated above, without the hinderance of a cage, rescuers may be able to better access and navigate an injured worker down off from a roof, off a platform, or anywhere along the length of the fixed ladder.  Planning for a potential rescue through safer design is vitally important for both the rescue team and the victim at a critical time when every minute counts.  Although OSHA points out that it does not prohibit employers from also installing cages, in addition to new requirements; they do stress that employers must ensure that the cages and wells are compatible with and do not interfere with the ladder safety or personal fall arrest systems.

Falls continue to be a leading cause of injuries and fatalities in the workplace.  OSHA’s fall protection requirements on fixed ladders are vital to help keep your employees safe.  Ensure your company leaders and those in charge of safety understand all aspects and intentions of this standard to maintain a safe workplace.

References

1. OSHA Regulation 29 CFR Part 1910 Subpart D Walking and Working Surfaces: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910SubpartD
2. Final Rule to Update General Industry Walking-Working Surfaces and Fall Protection: https://www.osha.gov/walking-working-surfaces
3. California Code of Regulations Subchapter 7 General Industry Safety Order Article 4. Access, Work Space, and Work Area §3277. Fixed Ladders: https://www.dir.ca.gov/title8/3277.html
4. Final Rule. Walking-Working Surface and Protective Equipment (Fall Protection Systems)- A Rule by the Occupational Safety and Health Administration on 11/18/2016: https://www.federalregister.gov/documents/2016/11/18/2016-24557/walking-working-surfaces-and-personal-protective-equipment-fall-protection-systems