OSHA recently published a proposed rule to remove the Nov. 18, 2036, deadline in its Walking-Working Surfaces standard. This standard would have required all fixed ladders extending more than 24 feet above a lower level to be equipped with personal fall arrest systems or ladder safety systems by this deadline.
Background
One of the more notable changes introduced by the 2016 rule was a phased-out requirement for cages and wells on fixed ladders, a traditional method of fall protection on tall ladders. While cages and wells give workers a sense of enclosure, research has shown that they provide little actual protection in the event of a fall and can even complicate rescue operations.
In their place, the 2016 rule required employers to transition to personal fall arrest systems or ladder safety systems, which are designed to actively stop or arrest a fall rather than simply surround the worker. Employers were given a lengthy transition window, until November 2036, to retrofit existing fixed ladders extending more than 24 feet above a lower level.
In July 2025, OSHA received a letter from industry groups petitioning to repeal the requirement for personal fall arrest systems on all fixed ladders extending more than 24 feet above a lower level. The petition requested that employers be allowed to continue using cages and wells or, alternatively, that such systems be permitted while requiring personal fall arrest or ladder safety systems only on ladders installed or modified after a new final rule is issued.
New Proposed Rule
The new proposed rule, published on April 6, 2026, is intended to provide greater compliance flexibility for employers by removing the deadline for installing personal fall arrest systems or ladder safety systems on all fixed ladders that extend more than 24 feet above a lower level. Employers would still be required to install safety systems on any new ladders or replacements. The change would allow employers to update ladders when they reach the end of their service life, helping to lower costs while maintaining safety standards.
What’s Next?
Employers should continue to comply with current OSHA standards, particularly ensuring that all new or replacement ladders are equipped with fall arrest or ladder safety systems. Rather than adhering to the 2036 deadline, organizations should consider reassessing long-term retrofit plans and aligning future upgrades with lifespan and risk-based evaluations.
OSHA is seeking comments on the proposed rule. Employers may submit comments on or before June 5, 2026, and they should monitor the rulemaking process to adjust compliance strategies once a final rule is issued.
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This document is not intended to be an exhaustive source of information nor should any discussion or opinions be construed as legal advice. Readers should consult legal counsel or a licensed insurance professional for appropriate advice. © 2026 Zywave, Inc. All rights reserved.
