OSHA Proposed Rule: Removal of 2036 Deadline for Fall Protection on Fixed Ladders
AI-generated summary for informational purposes only. Not legal advice. See the original source for the authoritative text.
OSHA is proposing to eliminate the November 18, 2036 compliance deadline that currently requires all existing fixed ladders extending more than 24 feet above a lower level to be equipped with personal fall arrest systems or ladder safety systems. The requirement for all new or replacement fixed ladders to have these systems remains in place. This change would allow employers to continue using fixed ladders with cages or wells until the end of their natural service life, avoiding expensive retrofits. The proposal responds to an industry petition from the fuel, petrochemical, chemical, and petroleum sectors claiming that retrofitting costs are extremely high while providing very little additional safety benefit, given the low number of ladder-related incidents.
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Key Changes
- Removes the November 18, 2036 deadline in 29 CFR 1910.28(b)(9)(i)(D) for retrofitting existing fixed ladders >24 ft
- Maintains requirement that all new fixed ladders must have personal fall arrest or ladder safety systems
- Maintains requirement that any replaced section of ladder, cage, or well must include fall arrest/safety system
+ 3 more changes with Pro
Obligations
What this law requires
Submit written comments on the proposed rule removal of the November 18, 2036 deadline for fixed ladder fall protection systems on or before June 5, 2026
Ensure that all new or replacement fixed ladders extending more than 24 feet above a lower level are equipped with personal fall arrest systems or ladder safety systems
Submit comments electronically through https://www.regulations.gov with Docket No. OSHA-2025-0072 clearly identified
Number all attachments sequentially when uploading multiple documents to https://www.regulations.gov for identification purposes
Notify OSHA if requesting an informal public hearing on the rule during the comment period