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Beyond the OSHA Top 10: Working at Elevated Heights


Each year, to more than a little fanfare, OSHA reveals which of its regulations have been violated most often by employers across the country. Based on the number of citations given and known as the OSHA Top 10, the list reveals two conflicting truths:

  • The Top 10 changes very little each year.
  • A more relevant safety story can be found by digging just a little deeper.

In 2021 – as it has been for more than a decade – the No. 1 most cited violation was the construction standard Fall Protection – General Requirements. About half the top 10 is related to working at elevated heights. Regulations around Ladders, Scaffolding and Fall Protection – Training Requirements make annual appearances.

Though the list of violations rarely changes, injuries from workplace falls have been rising. Data from the U.S. Bureau of Labor Statistics showed increases in workplace injuries from falls, slips and trips from 2016-19, before COVID-19 sent non-essential workers home for months and skewed the data:

  • A 14.7% increase in non-fatal injuries involving days away from work for all falls, slips and trips
  • A 9.2% increase in these injuries for falls of 6 feet or more
  • A 4.9% increase in these injuries for falls of less than 6 feet

So, workers are being hurt more often in falls from elevated heights, while companies continue to violate federal regulations designed to keep this from happening. It seems like a simple cause-and-effect relationship. But a peek beneath the hood finds a range of factors both driving this data and also helping to spark changes.

In June 2022, four board-certified Field Safety Specialists from Grainger discussed the data and the trends they see across the nation among employers big and small to provide greater context and insights.

  • Mike Carroll, CSP, West Coast Region
  • Meg McCormick, CSP, Northeast region
  • Ken Baas, CSP, Southeast region
  • Mac McCollum, CSP, Central Region

Trend No. 1: Walking Working Surfaces Standard Needs Attention

The consultants say that the Walking Working Surfaces Standard, effective in its current form in early 2017, deserves more focus from employers.

This general industry rule included a variety of requirements, with most compliance deadlines between 2017 and 2018. However, organizations have until November 2036 to replace cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders extending more than 24 feet above a lower level. Though 2036 seems like a long way off, specialists say it’s important to start considering now the costs and complexity associated with that change.

“When you think about managed fall protection systems and ladders in general, the old system that required you to have a cage for any ladder 24 feet or greater, except for the bottom 8 feet – it was a target system more than it was a fall protection system,” Carroll said. “It allowed the body to land in a certain location. It didn't really alleviate the problem of falling.”

Baas said he’s now seeing customers that have many fixed ladders greater than 24 feet in height throughout their operations are trying to get a head start.

He continued: “And I could also say on the flip side of that, there are a lot of customers that aren't preparing and I'm afraid they're going to wait till the last minute and have this enormous cost or burden to start replacing all these, not replacing ladders, but installing fixed restraints.”

McCollum said he spent a full day investigating fixed ladders at a location to see where they could be replaced with alternating stairs, and also walking through best practices for installing fall protection systems.

Trend No. 2: More Building = More Falling?

Falls from elevated heights are tightly linked with construction. Specialists see a couple of related trends that could be driving the increase in injuries noted above.

First is an increase in residential construction. New housing starts grew almost 10% from April 2016 to April 2019, according to data from the U.S. Census Bureau. After a swift plunge caused by the pandemic beginning in early 2020, numbers rebounded to that previous mark and beyond, showing a 45% increase from April 2016 to April 2022.

Greater demand for homebuilding means greater demand for homebuilders, and there is where a safety issue may arise.

“You have employees that don't have the skillset they had five years ago coming into the industry,” Carroll said. “Literally the skillset has changed drastically because there's just not enough employees to fill these roles. So, the qualification of those employees is substantially limited and less.”

That limited skillset goes beyond framing and plumbing to safety understanding. And in that, a second piece of the data comes into focus. Between 2012 and 2021, OSHA has more than doubled the number of violations of subpart 1926.503(b)(1) under Fall Protection – Training, which cites the lack of a written certification record of the training.

Carroll noted that OSHA enforcement of Fall Protection is generally limited to a handful of standards, as opposed to something like Respiratory Hazards, where if there’s one citation, there could be 30. Lack of written standards is a bit of low-hanging fruit for inspectors.

Trend No. 3: Engineering Controls Taking Hold

One area of OSHA citations that has dropped significantly in the last 10 years is among certain Scaffolding subparts. Specifically, 1926.451(g)(1), which requires each employee on a scaffold at least 10 feet high will have fall protection, and 1926.451(e)(1), which requires certain types of access for platforms more than 2 feet above or below that access point, are each down more than 60%:

McCormick said that a couple of situations where scaffoldings fell over in recent years raised awareness.

“I feel like that has helped in a bad way contribute to people or companies being better about ensuring they have competent people to erect them and take them apart and inspect them on a daily basis,” she said. “And I think there's better equipment out there for scaffolding as well.”

Baas, who sees many customers in his area taking a critical look at legacy fall protection systems they may have engineered themselves, went one step further: “I'd like to think that customers are engineering out, maybe not in all cases, but perhaps they're using the hierarchy of controls to a better extent to eliminate the need for scaffolding and how they engineer their systems and processes.”

Ladder violations have remained somewhat steady over the last decade, but Carroll noted they have become a point of special emphasis for some large companies.

“These large customers, they're outlawing ladders in their facilities,” he said. “It is crazy to say that, but that's what's occurring. And they're basically saying, unless you can get a written documentation to verify that you cannot do this job from an articulating boom lift or some sort of other engineering solution, you can't use ladders.”

Trend No. 4: Financial Pressures Making Impact

Money is a consideration for any business in all matters. When it comes to safety, two of the primary drivers are spending money on proper equipment and the fear of potential OSHA fines. According to OSHA data, the agency levied more than $270 million in total fines for violations issued in 2021.

But specialists say they are seeing increasing pressure from another direction, one which may be sparking action in some employers.

“I do feel like insurance companies are starting to have more of a say and especially workers comp providers,” McCormick said. “They’re making more requirements for actually having programs in place and making sure employees are trained and having the right equipment.”

For that to actually happen in a facility, however, Carroll noted that a strong business case is essential.

“You start talking about ROI, you start figuring out, how long does it take us to erect a scaffold? Or how long does it take that employee to grab that ladder and erect the ladder and figure it out and tie off and how much time does it take? And then you start coming into the gray areas of, what are we hoping to prevent? And what's the cost of that?"

Carroll continued: "That dollarization of it is what safety managers need to get the power and the resources to make the changes that they need to make."


The information contained in this article is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This article is not a substitute for review of current applicable government regulations, industry standards, or other standards specific to your business and/or activities and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.