OSHA answers five (5) questions regarding the relatively new standard, 1910.28 Duty to have fall protection and falling object protection. And I have to admit I found a couple of their answers interesting.
Question 1: 29 CFR ยง 1910.28(b)(9) requires fixed ladders (installed on or after November 19, 2018) that are more than 24 feet above the lower level, to be equipped with a personal fall arrest system or ladder safety system. If the fixed ladder is 24 feet or less, does a safety system (personal fall arrest system or ladder safety system) still need to be in place, as employers are still responsible to provide fall protection when employees are exposed to fall hazards of 4 feet or more?
Question 2: If a fixed ladder is 24 feet or less and requires a fall protection system, can a cage be used as a fall protection system?
Question 3: Would simply maintaining 3 points of contact suffice for fixed ladders below 24 feet in height?
Question 4: If a fixed ladder goes up 20 feet to a platform and then goes to another fixed ladder that is an additional 20 feet, would that then count as a combined 40 foot fixed ladder and need a safety system?
Question 5: If the above is not considered a combined 40 feet in height ladder, is it then considered two 20 foot fixed ladders not requiring a personal fall arrest or ladder safety system?