OSHA Proposes Rule to Remove Its Walking-Working Surface Standard Deadline

On April 6, 2026, OSHA published a proposed rule to remove the Nov. 18, 2036, deadline in its Walking-Working Surfaces standard that would have required all fixed ladders extending more than 24 feet above a lower level to be equipped with personal fall arrest systems or ladder safety systems. Additionally, OSHA is seeking comments on repealing or revising the requirement that employers use personal fall arrest systems on all fixed ladders over 24 feet tall and instead permitting employers to continue using ladder cages or wells.

Comments concerning the proposed rule must be received on or before June 5, 2026.

Background

OSHA finalized the current Walking-Working Surfaces standard in 2016 (81 FR 82494). The standard contains fall protection requirements for fixed ladders that extend more than 24 feet above a lower level, among other provisions. In the 2016 final rule, OSHA noted that the revised standard reflected advances in technology and was consistent with more recent OSHA standards and national consensus standards (81 FR 82494).

On July 28, 2025, OSHA received a letter from industry groups petitioning the agency to initiate rulemaking to repeal the requirement for personal fall arrest systems on all fixed ladders extending more than 24 feet above a lower level. The petition requested that employers be allowed to continue using cages and wells or, alternatively, that such systems be permitted while requiring personal fall arrest or ladder safety systems only on ladders installed or modified after issuance of a new final rule.

Key Highlights

This proposed rule is intended to provide greater compliance flexibility for employers by removing the Nov. 18, 2036, deadline for installing personal fall arrest systems or ladder safety systems on all fixed ladders that extend more than 24 feet above a lower level.

The requirement to ensure that any new or replacement fixed ladders are equipped with a personal fall arrest system or ladder safety system would be maintained. Consistent with the agency’s original intent for this provision, this change will allow employers to update their ladders when they reach the end of their service life, accommodating the long service life of fixed ladders while significantly reducing costs and offering greater flexibility.

Employer Takeaway

Employers should continue complying with current OSHA requirements, particularly ensuring that all new or replacement fixed ladders over 24 feet are equipped with personal fall arrest or ladder safety systems. At the same time, organizations should reassess long-term retrofit plans and align future upgrades with asset lifecycle and risk-based evaluations rather than a fixed 2036 deadline. Employers may also consider submitting comments before June 5, 2026, and should monitor the rulemaking process to adjust compliance strategies once a final rule is issued.

Article Published By: Zywave, Inc.