Industrial ladder design in the wake of OSHA 1910.28 revisions

[stewbaby]

It is my understanding that OSHA 1910.28(b)(9) will no longer accept cages as fall protection on new ladder installs in a little over a year from now. My typical ladder application is on small diameter 40' tall oil / asphalt storage tanks or refinery columns / towers. If I buy a tank tomorrow it seems it would be wise to go ahead and specify either a ladder safety system or fall arrest system. From a psychological standpoint though, I can see operations still wanting the cages though as well as rest platforms more often than what OSHA now requires (up to 150' now per (b)(9)(ii)(B) or 50' if we use a cage per (b)(9)(iii)(B)). Does anyone in the tank, tower/column, fall arrest industry have any guidelines to share on how they are approaching this?

The sections from OSHA most pertinent to my question:
1910.28(b)(9)(i)
For fixed ladders that extend more than 24 feet (7.3 m) above a lower level, the employer must ensure:
1910.28(b)(9)(i)(A)
Existing fixed ladders. Each fixed ladder installed before November 19, 2018 is equipped with a personal fall arrest system, ladder safety system, cage, or well;
1910.28(b)(9)(i)(B)
New fixed ladders. Each fixed ladder installed on and after November 19, 2018, is equipped with a personal fall arrest system or a ladder safety system;
1910.28(b)(9)(i)(C)
Replacement. 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
1910.28(b)(9)(i)(D)
Final deadline. On and after November 18, 2036, all fixed ladders are equipped with a personal fall arrest system or a ladder safety system.
1910.28(b)(9)(ii)
When a one-section fixed ladder is equipped with a personal fall protection or a ladder safety system or a fixed ladder is equipped with a personal fall arrest or ladder safety system on more than one section, the employer must ensure:
1910.28(b)(9)(ii)(A)
The personal fall arrest system or ladder safety system provides protection throughout the entire vertical distance of the ladder, including all ladder sections; and
1910.28(b)(9)(ii)(B)
The ladder has rest platforms provided at maximum intervals of 150 feet (45.7 m).
1910.28(b)(9)(iii)
The employer must ensure ladder sections having a cage or well:
1910.28(b)(9)(iii)(A)
Are offset from adjacent sections; and
1910.28(b)(9)(iii)(B)
Have landing platforms provided at maximum intervals of 50 feet (15.2 m).
1910.28(b)(9)(iv)
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.

 

[canwesteng]

Could you not put landings every 24 feet and have no fall arrest system, or do the landings not count as a lower level? In my jurisdiction we need landings every 20', plus a cage for the ladders above the first landing (makes sense, you could flying off the ladder and miss intermediate landings).

 

[stewbaby]

Definitely need OSHA to define a 'lower level' I guess. There definition doesn't help (Lower level means a surface or area to which an employee could fall. Such surfaces or areas include, but are not limited to, ground levels, floors, roofs, ramps, runways, excavations, pits, tanks, materials, water, equipment, and similar surfaces and structures, or portions thereof).

 

[stewbaby]

Nobody looking into this yet? Just wanting to discuss opinions / interpretations. I know I can fire off inquiries / clarification request to OSHA but was wanting to see what others in the industry were doing first. The less than 24' ladder 60' up on a process tower without a cage or ladder safety system just doesn't feel right...even if the 'lower level' landing platform were larger than normal and more likely to catch a fall.

 

[JStephen]

Looking at the wording of it, it sounds to me like you are no longer allowed to use offset ladders with intermediate platforms for heights over 24'. If the landing were large enough that you couldn't very well miss it on the way down, that would be different, but the normal small platforms wouldn't qualify
The general solution is going to be to put safety climbing rails on all ladders, I expect.