Ladder Safety Systems vs. Personal Fall Arrest Systems: What OSHA Really Requires

Michele Oras
4 days ago
4 min read

When you're responsible for facility safety, you spend a lot of time weighing equipment options—especially when it comes to fall protection. One question we hear all the time: “Do I need a ladder safety system or a personal fall arrest system (PFAS)?”

An image of Scrabble tiles spelling 'regulation'

The answer isn’t always straightforward. That’s because OSHA doesn’t just look at the type of ladder or the climb distance—it looks at total fall potential. And if you’re relying on cages to meet compliance? That clock is ticking.

For buildings where access is under 20 feet—like schools, QSRs, or light industrial facilities—products like the LadderPort Ladder Receiver can help standardize and secure access while staying within OSHA and ICC guidelines.

This post breaks down the differences between ladder safety systems and PFAS, the actual OSHA language behind the 24-foot rule, and real-world clarifications that show how compliance plays out in practice.

Why This Matters: The Stats Tell the Story

According to OSHA, 20% of all fatal and lost workday injuries in general industry involve ladders.

And in 2020 alone:

161 workplace fatalities from ladders
22,710 workplace injuries from ladders
5,790 ladder injuries in installation, maintenance, and repair jobs
5,370 ladder injuries in construction and extraction jobs

Sources:

These statistics highlight the real and ongoing risk associated with ladder use. Proper fall protection is a critical part of preventing injuries and fatalities.

Ladder Safety System: Built to Prevent the Fall

Ladder safety systems are designed to reduce or eliminate the risk of falling while climbing. They consist of:

A carrier (cable or rail)
A safety sleeve that travels with the user
A body harness and lanyard

When used correctly, these systems offer continuous, hands-free protection as the worker ascends or descends. If a slip occurs, the system engages quickly, limiting fall distance.

Important: OSHA no longer recognizes ladder cages or wells as acceptable fall protection for new ladders.

PFAS: Stops the Fall Mid-Air

Personal fall arrest systems are designed to arrest a fall once it begins. PFAS includes:

Full-body harness
Anchor point
Connector (lanyard or lifeline)
Deceleration device

It’s reactive—not preventative. PFAS doesn’t stop the slip from happening, but it limits injury by arresting the fall and controlling forces on the body.

The 24-Foot Rule: What OSHA Actually Says

OSHA’s 29 CFR 1910.28 is clear:

If a worker could fall more than 24 feet from a fixed ladder, you must install a ladder safety system or a personal fall arrest system.

Here’s how it breaks down:

Ladders installed on or after November 19, 2018: Must have a ladder safety system or PFAS—cages are not allowed.
Ladders installed before that date: Can still use cages temporarily, but must be retrofitted with a ladder safety system or PFAS by November 18, 2036.

And this isn’t about the length of a single ladder section. It’s about the total fall distance from the point of exposure to the next lower level.

OSHA Clarification Letters: Real Examples

May 17, 2019 – Elevated Tower Climb

Scenario: A 24-foot vertical climb starts 100 feet off the ground on a tower. OSHA ruled that a fall from that height—despite the short ladder segment—still requires fall protection. Why? Because the fall distance exceeds 24 feet.

Read it at: www.osha.gov/laws-regs/standardinterpretations/2019-05-17

October 18, 2019 – Grain Silo With Rest Platforms

Scenario: A series of offset ladders is installed with 3’x3’ rest platforms. OSHA determined that a worker could still fall more than 24 feet past those platforms. The platforms don’t reset the fall distance—a ladder safety system or PFAS is still required.

Read it at: www.osha.gov/laws-regs/standardinterpretations/2019-10-18

What About Emergency-Use Ladders?

If a fixed ladder is installed only for emergency egress (and is clearly labeled “Emergency Use Only” at both ends), OSHA allows an exception. But the minute that ladder is used for regular access—it must comply with 1910.28.

Bottom line: If the ladder is ever used in non-emergency conditions, don’t rely on signage alone. Install proper fall protection.

Choosing the Right System

System Type	Purpose	Key Components	OSHA Compliant for Fixed Ladders ≥24′
Ladder Safety System	Prevent a fall while climbing	Carrier, shuttle, harness, lanyard	Yes – required on new ladders or when retrofitting
Personal Fall Arrest System (PFAS)	Arrest a fall in progress	Harness, anchorage, lifeline, deceleration device	Yes – an acceptable alternative to ladder safety systems
Ladder Cage	Historically used to contain a fall	Cage/well	No – phased out by 2036

Final Takeaways for Safety Professionals

Fall protection is based on exposure, not ladder section length.
Cages are not acceptable for new ladders and will be fully phased out by 2036.
OSHA’s clarification letters show that even short climbs high off the ground still require protection.

Plan now. Retrofit early. Don’t wait until compliance is enforced—by then, it could be too late.

Where LadderPort Fits

LadderPort products are designed for key points of access where compliance and consistency matter most.

LadderPort Ladder Receivers: Ideal for applications where an extension ladder provides access to a fixed ladder. Approved for use on buildings up to 20 feet high per OSHA, and 16 feet per the International Code Council.
Roof Hatch Grab Bars: Improve safety at ladder-to-roof transitions—whether or not the ladder has a safety system installed. Often used in conjunction with fixed ladders and cages where applicable.

Whether you're retrofitting a school, QSR, or light industrial facility, LadderPort offers solutions that support code-conscious access and worker safety.