Fall Protection:

Nothing Prevents Complacency Like Training and Retraining

by Diane M. Calabrese| Published September 2025

 

 

We know that if we climb a ladder with a cracked rung, we take a risk. And we know climbing a ladder with a cracked rung violates an OSHA (Occupational Safety and Health Administration) rule. The “why” of taking the risk doesn’t matter.

Whether it’s time compression or only a single ladder at the jobsite that stops us from making a change, stepping on a weak rung is dangerous. Members of our industry know well the many expectations OSHA has for the use of ladders, scaffolds, lifts, etc.

Fall protection expectations for our industry are covered in 29 CFR 1910 of OSHA Standards, specifically subparts D (walking-working surfaces), F (powered platforms, manlifts, and vehicle-mounted work platforms), and I (personal protective equipment).

An employer’s responsibility for safe walking and working surfaces encompasses all surfaces, not just elevated ones. Consequently, fall protection includes attention to all surfaces, whether at ground level or elevated.

Ground-level surfaces must be free of hazards: sharp objects, protruding objects, loose boards, corrosion, etc., and they must be able to bear the load to which they will be subjected.

In short, fall protection is a comprehensive enterprise. When the walking surface is above ground—a scaffold, for example—employees must be trained in use of the elevated platforms and rope descent.

Professional organizations and commercial enterprises offer training (and certification) in high work and fall protection. There’s much to know. For instance, workers ascending ladders over 24 feet must have a personal fall arrest system.

Some state regulations for fall protection exceed those from OSHA. Therefore, the state regulations supersede those from OSHA.

It’s not just arrest systems in which employees working high must be trained. They must also know how to secure scaffolds.

Scaffold safety includes understanding weight-bearing ability, bracket placement, and width and height. Lifts seem safer than scaffolds, but training is required in how to use them, including required inspections (prestart and routine maintenance).

Tip-overs and entanglements with wires make lifts not the simple, safe alternative to scaffolds that they may seem. Training, training, and more training ensures workers know and follow the proper protocols.

Is there a straightforward answer to which employees require arrest systems? Not exactly, as it depends on the state. But in general, anyone working higher than four feet in a general industry setting (including power washing) above ground should have an arrest system. (Elevation is six feet in construction.)

Four feet. Yes, we see contractors (perhaps soft washing) working on roofs frequently who do not have such protective gear, but they should.

Unsafe practices affect the entire industry. A company that scrupulously follows regulations for fall protection may suffer the consequences of other firms not doing the same. Insurance rates are calculated based on the “experience” (collection of incidents) in a region (or possibly a larger geographic area).

According to OSHA, falls are the most common causes of work-related injuries and death. According to NIOSH [National Institute for Occupational Health and Safety], falls from a ladder are common (20,000-plus each year) not just in the workplace but also outside work (NIOSH is part of the CDC.)

NIOSH puts a strong emphasis on ladder safety. It provides a ladder app that can be downloaded. The purpose of the app is to help ladder users attain the correct (safest) position for a ladder.

The safety risks associated with ladder use, according to NIOSH, are unprotected edges, unsafe positioning, misused protection, and soiled rungs. Unprotected edges on a ladder can result in snagging of clothing, which could cause the climber to lose balance.

If the ladder itself is not positioned correctly, it could slide out from under the climber. NIOSH reports that 40 percent of ladder mishaps occur because an extension ladder slides out from under the base. It advises a 75-degree angle when positioning an extension ladder.

Most important in ladder safety is to match the ladder to the job, advises NIOSH. And, of course, inspect the ladder—no cracked rungs, no grease or debris on rungs, etc. When one is on the ladder, follow the safe practices of not overreaching, not over-exerting (and adding a force to the ladder by using it for leverage), and not carrying things up and down that should not be carried.

The biggest safety risk in ladder use, according to NIOSH, is a lack of training. Employers must train workers and retrain them.

OSHA summarizes the approach to fall prevention in three parts: plan, use the right equipment, and train.

Plenty of assistance with safety training is available from OSHA. Begin with its primer “Plan. Provide. Train.” The primer includes links to educational resources (https://www.osha.gov/stop-falls/educational-resources) that include fact sheets on safe use of extension ladders, safe use of step ladders, and protection of roofing workers.

According to the Bureau of Labor Statistics (cited by OSHA), there were 421 fatal falls to a lower level (as opposed to tripping and falling at ground level) at work sites in 2023. That fits into an overall total for the same year of 1,075 falls. Moreover, falls from height is the second-leading unintentional fatal workplace event.

The seriousness of a fall to a lower elevation is easy to forget when engaged in work and deciding to simply get a quick lift from a ladder to gain better reach to the highest part of the exterior. With good planning many residential jobs can be completed without ever using a ladder. As OSHA training materials remind us, it’s all about good planning.

The planning includes being attentive to weather conditions. Obviously, no one should be on a metal ladder (or any ladder) in an electrical storm. And if working in heat, caution must be taken so that warm temperature does not impair judgement.

Sound judgement, or prudence, has a prosaic tone to it. That’s a good thing. On jobsites day in and day out, the best outcome is an ordinary span of work hours. Uneventful except in accomplishing the tasks at hand is the goal.

Ordinariness of a day should never result in complacency, though. Nothing prevents complacency like training and retraining.