OSHA published a proposed rule on April 6, 2026, that would remove the November 18, 2036 deadline requiring personal fall arrest systems or ladder safety systems on fixed ladders extending more than 24 feet above a lower level. The comment period closed on June 5, 2026. OSHA has scheduled informal public hearings starting on August 19, 2026, and has not yet issued a final rule.
Where the 2036 Deadline Came From
OSHA's 2016 Walking-Working Surfaces standard set November 18, 2036, as the date by which all fixed ladders over 24 feet needed a personal fall arrest system or ladder safety system installed. The rule was built around a specific safety argument: cages and wells limit lateral movement but don't stop a worker from falling if they lose their grip.
What the Proposal Would Change
The proposed rule removes the 2036 deadline entirely rather than shortening or extending it. Under the proposal, fixed ladders installed before November 19, 2018 could continue relying on a personal fall arrest system, ladder safety system, cage, or well for as long as they remain in service. New ladders and any replaced ladder sections would still need a personal fall arrest system or ladder safety system regardless of the deadline change.
OSHA is also asking a broader question in the same rulemaking: whether it should repeal or revise the requirement that every fixed ladder over 24 feet eventually carry a personal fall arrest system or ladder safety system.
The agency is requesting evidence on whether cages and wells deliver safety outcomes equivalent to those systems which, if OSHA concludes they do, would leave cages and wells acceptable indefinitely rather than only until a ladder is replaced.
Why Did Industries Push for This
Trade groups including the American Fuel & Petrochemical Manufacturers, the American Chemistry Council, and the American Petroleum Institute petitioned OSHA, arguing that retrofitting fixed ladders across large facilities is far more expensive than OSHA estimated in 2016. They cited the cost of inspecting and maintaining new safety equipment, training workers and contractors, and diverting resources from other safety projects.
OSHA said in the proposal that removing the deadline imposes no new compliance costs and could produce meaningful savings, since employers could avoid retrofitting ladders that are still within their useful service life.
The petitioners' own figures put the scale of the avoided spend at more than 22,000 ladders and over $1.2 billion across their member companies, which they extrapolated to roughly $3 billion industry-wide for refining.
What Happens Next
Falls, slips, and trips accounted for 844 workplace fatalities in 2024 out of 5,070 total, roughly 17 percent of all occupational fatalities, according to Bureau of Labor Statistics data. That context is part of why OSHA's request for comment on the underlying cage-and-well question, not just the deadline, drew attention during the comment period.
The rulemaking is still moving. On June 3, 2026, OSHA published a notice scheduling virtual informal public hearings beginning August 19, 2026, covering 19 deregulatory proposals including this one. Parties who wanted to testify had to file a notice of intent to appear by July 6 and submit their full testimony and documentary evidence by August 5.
Employers with fixed ladders installed before November 19, 2018 may want to hold off on retrofit spending until OSHA issues a final rule, rather than moving ahead based on the original 2036 timeline.
Facilities weighing what to prioritize while this rule moves through review can lean on a documented risk register to track which fall hazards need attention regardless of how the final ladder rule lands.
References: Federal Register, "Walking-Working Surfaces" | IHMM, "Analysis of the OSHA Proposed Walking-Working Regulation" | Certify Consulting, "OSHA's Walking-Working Surfaces Rule Is Changing"
Mehreen Iqbal
Started with a Bachelors in Microbiology, then a Masters in Public Health; Currently a Workplace Safety Expert.