OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 28, 2021

Kelly Meeks, CSP
Ergon, Inc. Corporate Health and Safety Specialist
103 Northridge Rd.
Madison, MS 39110

Dear Ms. Meeks:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA), requesting clarification on the usage of platforms and fall protection for fixed ladders. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. The questions you provided in your inquiry are paraphrased below and OSHA’s responses follow.

Question 1: What is an acceptable size of the resting platform for fixed ladders that extend less than 24 feet above a lower level?

Response: 29 CFR 1910.29(g)(4) requires that platforms used with fixed ladders provide a horizontal surface of at least 24 inches by 30 inches (61 cm by 76 cm). However, for the resting platform to be considered a lower level (i.e., a surface or area to which an employee could fall), it needs to be of sufficient size and sufficiently protected so that if a worker was climbing the fixed ladder, the worker could not fall past the platform. If a worker could fall from the platform more than 24 feet to the ground or a lower level, the employer must equip the ladder with fall protection.

Question 2: Should there be a company-wide standard for the installation of a personal fall arrest or ladder safety system?

Response: Employers are required to meet 29 CFR 1910.28 requirements. The method by which an employer decides to address the standard is a management decision.

Question 3: Can we provide a cage on the ladder, which extends to the handrails on the platform below, in order to ensure that an employee would not fall outside of the platform?

Response: Cages or wells may be provided to ensure that an employee would not fall outside of a platform. As specified in 29 CFR 1910.29(g)(3), cages and wells must be designed, constructed, and maintained to contain employees in the event of a fall, and to direct them to a lower landing. However, cages may not be used on the fixed ladders installed after November 19, 2018, as a primary means of fall protection. Such ladders must be equipped with either a personal fall arrest system or a ladder safety system, in accordance with 29 CFR 1910.28(b)(9)(i)(B).

Question 4: Will the installation of a ladder cage interfere with a rescue on a ladder equipped with a personal fall arrest system or ladder safety system?

Response: Under 29 CFR 1910.28(b)(9)(iv), for fixed ladders that extend more than 24 feet (7.3 m) above a lower level, the employer may use a cage or well in combination with a personal fall arrest system or ladder safety system provided that the cage or well does not interfere with the operation of the system. The employer may not install a cage or well in combination with a personal fall arrest system or ladder safety system if it interferes with rescue operations.

Question 5: What are OSHA requirements regarding rest platforms installed with fixed ladders that extend more than 24 feet above a lower level?

Response: 29 CFR 1910.28(b)(9)(ii)(B) requires that ladders equipped with a personal fall protection or a ladder safety system shall have rest platforms provided at maximum intervals of 150 feet (45.7 m). 29 CFR 1910.28(b)(9)(iii)(B) requires that ladder sections, which have a cage or a well, have landing platforms at maximum intervals of 50 feet (15.2 m).

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,

Kimberly Stille, Acting Director
Directorate of Enforcement Programs