California triggers at 20 feet. The federal rule triggers at 24.
Cal/OSHA, Title 8 CCR §3277(g)(2) requires cages or wells on fixed ladders of more than 20 feet, to a maximum unbroken length of 30 feet. Federal OSHA, 29 CFR 1910.28(b)(9), sets its trigger at more than 24 feet. Cal/OSHA enforces the California standard in California workplaces, so a facility that inventoried at 24 feet has a four-foot blind spot.
The trigger most facilities miss is not a height at all. Under 29 CFR 1910.28(b)(9)(i)(C), when a fixed ladder or any section of one is replaced, a personal fall arrest system or ladder safety system must be installed in at least that section at that time. That obligation applies today. Any fixed ladder installed on or after November 19, 2018 must already have one.


