The OSHA regulations and ANSI standards impacting ladder safety are changing. Specifically, the requirements for cable sleeves used on climbing ladder fall arrest systems, the fall protection equipment needed for these applications, and other elements of a vertical climbing system. If you use a climbing ladder system then these changes likely apply to you. Additionally, industries not previously required to comply, such as outdoor advertisers (e.g., billboards), are included.
In November of 2016, OSHA published its final rule on ‘Walking and Working Surfaces’, updating the existing standard. These new updates apply to all general industry workplaces, including changes to fixed ladders and fall arrest systems, and provide as follows:
- By November 19, 2018, you must install fall protection (personal fall arrest systems, ladder safety systems, cages, wells) on existing fixed ladders over 24 feet that don’t currently have fall protection.
- By November 19, 2018, you must install ladder safety or personal fall arrest systems on newly fixed ladders over 24 feet and replacement ladders/ladder sections.
Furthermore, in February of 2017, ANSI introduced the new Z359.16 standard for Climbing Ladder Fall Arrest Systems, which sets out requirements that equipment must meet to be compliant, complementing the OSHA standards. These changes became effective in August of 2017, but the deadline by when you need to be compliant varies.
These changes are happening now. In this article, we outline five things to consider when making changes to comply.
Know Who Needs to Comply
Generally, any industry with applications that require the use of a climbing ladder safety system—wind energy, telecom and utilities, oil and gas, general industry, and agriculture — needs to review the OSHA Walking Working Surfaces rule and ANSI’s Z359.16 standard. While you may already be using fall protection equipment or climbing ladder fall arrest systems, there have been updates to the required components on those pieces of equipment or modifications to height thresholds.
People working at height on billboards and outdoor advertising, known as “qualified climbers,” will now also need fall protection, and fixed ladders over 24 feet will require a ladder safety system. The final OSHA Walking Working Surfaces rule marks a dramatic change in requirements. Outdoor advertising employers are currently only required to install fall protection (i.e., ladder safety systems) where the length of a climb exceeds 50 feet or the height of the ladder extends more than 65 feet above grade. In other words, the new rule reduces the height threshold that will trigger the need for a ladder safety system and fall protection equipment.
Identify Your Competent Person
Both OSHA and ANSI have specific requirements for the competent person. Generally, a competent person is the individual responsible for the immediate supervision, implementation and monitoring of a managed fall protection program. Depending on the size of the team, responsibilities may also include ensuring personal protective equipment (PPE) is in good working order, meets current regulations and standards and they are responsible for training the workers using the equipment to confirm it is set up and used properly.
Select the Right Type of Fall Protection Equipment
A competent person, as defined by OSHA, must determine the appropriate full-body harnesses for use conforming to ANSI/ASSE Z359.11 and the manufacturer’s instructions, including:
- D-ring position
- Lanyard keepers
- And, per ANSI Z359.16, they must also be supplied with a linkage to the harness, which cannot exceed 12 inches.
When selecting the climbing ladder fall arrest system and related components, ANSI Z359.16 calls out specific requirements for the equipment to be compliant. Depending on what you currently use, these requirements may necessitate you reevaluating and changing your current fall protection equipment so that:
- Carrier sleeves must now include an anti-inversion feature to help prevent the user from inadvertently installing the carrier sleeve upside down.
- Each system must support between two and four climbers at the same time.
- During climbing and descent, sleeve movement should be automatic, not requiring continuous manual intervention.
- The sleeve must automatically lock during a fall and must also include a second independent locking mechanism that cannot be disengaged or interfered with during a fall.
- The average arrest force should not exceed 1,350 pounds and the maximum arrest force should not exceed 1,800 pounds.
- The maximum movement of the sleeve when locking onto the carrier cable in a fall event cannot exceed 20 inches.
- Sleeves designed to be removable from the carrier cable must require at least two deliberate manual actions by the user.
Update Your Ladder with a Vertical Fall Arrest System
Fixed ladder cages and wells will be phased out and will have to be replaced with ladder safety systems or personal fall arrest systems, such as vertical system solutions. This must happen on all fixed ladders over 24 ft. by November 18, 2036.
This new standard applies to any vertical climbing system that’s 90 degrees (plus or minus one degree) when viewed from the front elevation and within 15 degrees of vertical from the side elevation.
There are ANSI compliant flexible cable vertical safety systems available that can help you comply with these new standards and regulations. You may also look for a system that has integrated fall-arrest anchor points and can be mounted on a variety of fixed ladder sizes and styles.
Comply by 2018 or 2036
To recap the dates by which you need to comply. The earliest date, required by OSHA, is November 19, 2018. By this date you must:
- Install fall protection on existing fixed ladders over 24 feet that don’t currently have fall protection, and
- Install ladder safety or personal fall arrest systems on newly fixed ladders over 24 feet and replacement ladders/ladder sections
- Make sure that any existing fixed ladders being repaired or replaced must comply with the new regulation for installation of a fall protection system.
The latest date, also required by OSHA, is November 18, 2036. All fixed ladder cages and wells must be phased out by this date and replaced with ladder safety systems or personal fall arrest systems, such as vertical system solutions.
Not sure where to start? Consider getting an onsite assessment to evaluate your PPE and safety needs. We can help you schedule a complimentary onsite assessment today. Contact us at 1-800-328-6146 today.
Safety Now & Next Blog: Walking the Walk… Tips for Complying With the Final OSHA Walking-Working Surfaces Rules
ANSI Z359.16 Standard for Climbing Ladder Fall Arrest System (YouTube Video)