OSHA Proposes Removing 2036 Deadline for Fixed Ladder Fall Protection Upgrades
According to ISHN, OSHA has proposed removing the 2036 deadline from its Walking-Working Surfaces standard that required employers to retrofit fall arrest or ladder safety systems on all fixed ladders extending more than 24 feet above a lower level. The original mandate, set in a November 2016 final rule, gave employers until November 18, 2036, to complete upgrades. Under the proposed change, employers could instead make upgrades when ladders reach end of service life. New fixed ladder installations would still require compliant fall protection systems from the start. Written comments are due June 5 via regulations.gov, Docket No. OSHA-2025-0072.
What It Means for Subcontractors
- If you’ve already budgeted for fixed ladder retrofits ahead of the 2036 deadline, that spend may no longer be legally required on the original schedule. Hold off on major commitments until the rule is finalized.
- The relief applies only to existing fixed ladders. Any new ladder installations still require a personal fall arrest system or ladder safety system from day one, so new-build and construction work is unaffected.
- The comment window closes June 5. If this change affects your operations, submitting comments through regulations.gov is the formal way to put your company’s position on the record.
