OSHA Is Phasing Out Ladder Cages— What Ammonia Refrigeration Facilities Need to Know | Blog No. 103

OSHA has finalized updates to its Walking-Working Surfaces and Fall Protection

standards that affect how fixed ladders over 24 feet are protected in the general industry.

For ammonia refrigeration facilities, the most common impact is not a single piece of

equipment, but fixed ladders that provide access to rooftops where ammonia piping,

Emergency ventilation fans, and sometimes evaporative condensers, are located.

When the Rule Applies

The updated OSHA requirements apply to fixed ladders that extend more than 24 feet

above a lower level. For new or replaced ladders above that height, ladder cages are no

longer permitted as a fall protection method. Instead, OSHA requires either a ladder

safety system or a personal fall arrest system.

Existing ladders that exceed 24 feet may continue to use ladder cages until November

18, 2036. After that date, those cages must be replaced with a ladder safety system or a

personal fall arrest system. Ladders that are 24 feet or less are not subject to this

specific requirement.

Two Different Compliance Paths

OSHA allows two distinct types of fall protection for tall fixed ladders, and while both are

Compliant, they function very differently in practice.

A ladder safety system is integrated directly into the ladder structure. These systems

use a vertical cable or rigid rail mounted to the ladder, along with a traveler or arrestor

that moves with the worker as they climb. The worker wears a full-body harness and

attaches to the traveler. If a fall occurs, the arrestor locks onto the rail or cable, stopping

the fall directly on the ladder itself. Because the system is part of the ladder, it guides

the worker continuously during ascent and descent without requiring manual tie-off at

each rung.

In ammonia refrigeration facilities, ladder safety systems are often well-suited for roof

access ladders that are used regularly for mechanical integrity inspections, valve maintenance, or piping walkdowns. They provide continuous protection and reduce

setup time for routine access.

A personal fall arrest system, by contrast, is a worn system rather than a ladder-

mounted one. In a PFAS, the worker wears a full-body harness and connects to a

lanyard or self-retracting lifeline that is anchored to a certified structural anchor point. If

a fall occurs, the fall is arrested by the anchorage and connecting device rather than by

the ladder itself.

PFAS is commonly used where ladder geometry, building configuration, or rooftop

layout makes it impractical to install a ladder-mounted rail or cable. Because PFAS

relies on anchorage points, it requires careful design, certification, and documentation,

along with worker training and inspection programs.

The key distinction is that a ladder safety system is integrated with the ladder structure,

while a personal fall arrest system is worn by the user and depends on an external

anchor.

Rooftop Access

In ammonia refrigeration facilities, fixed ladders most often provide access to roofs that

contain critical system components. These include ammonia piping and headers,

emergency ventilation fans, pressure relief vent piping, and, in some cases, evaporative

condensers.

These rooftops are accessed for routine inspections, maintenance activities, and

regulatory compliance tasks. When the ladder providing access exceeds 24 feet, the

ladder itself becomes a regulated piece of equipment under OSHA’s updated fall

protection requirements, regardless of what equipment is located on the roof.

Planning Ahead

Although existing ladders may remain in service for several years, facilities benefit from

addressing ladder compliance early. Confirming ladder heights, identifying which roof

access points exceed 24 feet, and evaluating whether a ladder safety system or

personal fall arrest system is more appropriate and can all be incorporated into mechanical

integrity planning and capital projects.

Because rooftop access is routine in ammonia refrigeration, early planning reduces

inspection risk and avoids rushed retrofits later.

Thank you for reading!

Previous Blog: Understanding What Belongs on Your Ammonia Refrigeration Machinery Room Placard Under the Latest IIAR Standards | Blog No. 102

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