OSHA’s Fixed Ladder Deadline: The 2026 Proposal and Where It Stands
Many plants and buildings have tall fixed ladders with a cage around them. OSHA’s rule says those cages have to be replaced with fall protection by November 18, 2036. In April 2026, OSHA proposed taking that deadline away. This page explains what the rule says today, what OSHA wants to change, and where the change stands right now. We will update it each time the rule moves.
What the rule says today
The rule is 29 CFR 1910.28(b)(9)(i). It covers fixed ladders that go more than 24 feet above a lower level. Today it has four parts:
- Old ladders. A fixed ladder put in before November 19, 2018 needs a personal fall arrest system, a ladder safety system, a cage, or a well.
- New ladders. A fixed ladder put in on or after November 19, 2018 needs a personal fall arrest system or a ladder safety system. A cage alone is not enough.
- Repairs. When you replace a ladder, cage, or well, or any part of a section, that section needs a personal fall arrest system or a ladder safety system.
- Final deadline. On and after November 18, 2036, every fixed ladder over 24 feet needs a personal fall arrest system or a ladder safety system.
That last part is why so many cages would have to come out by 2036. OSHA set it in its 2016 Walking-Working Surfaces rule.
What OSHA proposed
On April 6, 2026, OSHA published a proposed rule (91 FR 17165). It would:
- Remove the 2036 deadline (paragraph (D) above).
- Keep the other three parts. New ladders and replaced sections would still need a personal fall arrest system or a ladder safety system.
OSHA also asked the public whether it should go further: repeal or change the fall-arrest requirement for fixed ladders over 24 feet and let employers keep using cages and wells.
Why OSHA wants the change
OSHA says it is rethinking an assumption from 2016: how long a fixed ladder lasts. Fixed ladders often stay in service for a very long time. Without the deadline, employers would add fall protection when a ladder reaches the end of its life instead of tearing out working ladders early.
The cost numbers in the proposal show why this matters:
- In 2016, OSHA estimated about $1.2 million a year to retrofit roughly 109,200 affected fixed ladders.
- An industry petition said its members alone would spend more than $1.2 billion on more than 22,000 ladders. Those members are about one third of U.S. petroleum refineries.
- Using the petition’s numbers, OSHA estimated savings of over $3.6 billion in that one industry if the deadline goes away. OSHA asked for comments on whether those numbers are right.
Where the rule stands now
The comment period closed on June 5, 2026. As of October 15, 2026, OSHA has not published a final rule. That means:
- The rule today has not changed. The November 18, 2036 deadline is still in the standard.
- A proposed rule is not law. OSHA could finalize it as written, change it, or drop it.
- OSHA has not said when it will decide.
What to do now
- List your fixed ladders over 24 feet and when each one was installed.
- Check new and replaced ladders. Anything installed or replaced on or after November 19, 2018 needs a personal fall arrest system or a ladder safety system. That part is not changing.
- Keep cages and wells in good repair on older ladders. They still count for ladders installed before November 19, 2018.
- Plan replacements by service life. If the deadline goes away, upgrades can follow the ladder’s life. If it stays, you will need a plan before 2036.
- Train your crew on the ladder rules that apply today, including how to inspect and use a ladder safety system.
Frequently asked questions
Is the 2036 fixed ladder deadline gone?
Not yet. OSHA proposed removing it in April 2026, but no final rule has been published. Until then, the deadline is still in 29 CFR 1910.28(b)(9)(i)(D).
Do new fixed ladders still need fall protection?
Yes. A fixed ladder over 24 feet installed on or after November 19, 2018 needs a personal fall arrest system or a ladder safety system. The proposal keeps that rule.
Can I keep the cage on an older ladder?
For a fixed ladder installed before November 19, 2018, a cage or well meets the rule today. If you replace the ladder, cage, or well, or part of a section, that section needs a personal fall arrest system or a ladder safety system.
When will OSHA decide?
OSHA has not announced a date. We will update this page when the rule moves.
Sources
- Walking-Working Surfaces, proposed rule, 91 FR 17165 (April 6, 2026), Occupational Safety and Health Administration, Federal Register. Checked October 15, 2026.
- 29 CFR 1910.28, Duty to have fall protection and falling object protection, Electronic Code of Federal Regulations. Checked October 15, 2026.
- Docket OSHA-2025-0072, Regulations.gov (comments and the industry petition). Checked October 15, 2026.
- Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems), final rule, 81 FR 82494 (November 18, 2016), Federal Register. Checked October 15, 2026.
This is a plain-language summary, not legal advice. The official text is in the Federal Register and the eCFR.