The Federal OSHA Occupational Safety and Health Standards requirements for fall protection on fixed ladders were revised in October of 2016 with some new requirements becoming effective after November 19, 2018. This revision relates to all ladders including those installed on bolted and welded steel ground storage tanks. All new ladders installed after November 19, 2018 extending over 24’ above a lower level must include a ladder safety or personal fall arrest system. Existing ladders, defined as ladders installed before November 19, 2018 must be equipped with one of the following items: ladder cage, ladder safety system or personal fall arrest system. All new ladders installed after November 19, 2018 will not be able to use a ladder cage as the exclusive fall protection method. Ladder cages will still be able to be used provided they are combined with a primary fall protection method such as a ladder safety or fall arrest system and the cage does not interfere with the primary system. After November, 19, 2036 all existing ladders not in compliance with the requirements for new ladders will need to be retrofitted to have either a ladder safety or personal fall arrest system.
A ladder safety system is designed to eliminate the possibility of your employees falling from the ladder. Similarly, a fall arrest system stops the fall before the worker impacts the surface below.
Ladder Safety Systems Commonly Includes
- Lanyard
- Connectors
- Body harness
- Carrier
- Safety sleeve
Fall Arrest Systems Commonly Includes
- Lanyard
- Connectors
- Body harness
- Positioning system
- Travel restraint system/deacceleration device
Ladder Cages Commonly Includes
- Enclosure surrounding climbing space of ladder
For all new and existing fixed ladders with heights less than 24’ above a lower level, no fall protection is required by OSHA but ladder cages, ladder safety systems, or fall arrest systems can be used if desired.
| Ladder Height and Installation Date | Height above Lower Level | Fall Protection Required | Ladder Cage | Ladder Safety System | Fall Arrest System |
|---|---|---|---|---|---|
| Existing Ladders (installed before 11/19/18) | >24′ | Yes | M | M | M |
| New Ladders (installed after 11/19/18) | >24′ | Yes | O ² | M | M |
| All Ladders after 11/19/36 | >24′ | Yes | O ² | M | M |
| All Ladders | ≤ 24′ | No | O | O | O |
O = Optional, Not Required
M = Meets OSHA Requirement
¹ Only 1 of the acceptable fall protection methods is needed to satisfy OSHA requirements
² Cannot be used exclusively, Must be combined with Ladder Safety System or Fall Arrest System
Another change in the regulation is the requirement of resting platforms. After November 19, resting platforms are required at maximum 50’ intervals when a cage is used and 150’ maximum intervals when a personal fall arrest or ladder safety system is used. Under the old regulation the maximum distance was only 30’ for each segment and if a safety device was used on a ladder for tower, water tank or chimney, a platform was not required at all.
In addition to ladder systems, Superior Tank offers other equipment to keep your workers safe while working with ground storage tanks. For example, tie-points at various locations on the tank such as around the roof hatch provide a suitable anchor for fall protection systems. Also, extending roof railing and installing OSHA required self-closing gates at openings can also prevent worker falls.
Please note, your local regulations may differ as select areas have regulations independent of Federal OSHA Requirements. Our safety experts can recommend the right equipment to prevent injuries to your workers and comply with OSHA requirements to avoid fines and penalties. Contact us today to see how we can help!
