In it's pretty typical on industrial construction to provide a ladder to the roof (either exterior, or interior with a roof hatch). For cold storage, where roof access is more common and more frequent for maintaining the refrigeration system, we would provide either a ships ladder and or a stair tower.
After OSHA changed the rules from 20ft with an intermediate landing and cage to 24 ft without a cage, switching to a harness for fall protection, we had to get creative with alternate options to avoid the cost of installing and maintaining harness systems.
From an architectural standpoint, for 19 years, I designed ladders and ladders with intermediate landings. I recently partnered with a structural engineer whose solution was to provide the cage attached to the guardrail on the intermediate landing, so that the upper ladder would not be deemed greater than 24 ft.to the grade below. It's ironic because I contacted OSHA Representatives for months following the announcement of the change and none of them could give me a clear answer on the intermediate landing solution.
Typically, the structural engineer would either design the standard ladder from a steel fabrication standpoint as well as the structural attachment and or leave the ladder to be delegated designed by the steel fabricator.
Please let me know if you have any additional questions, from an industrial standpoint.
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Ben Trusty AIA
Atlanta GA
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Original Message:
Sent: 04-02-2026 06:08 PM
From: James McLane, AIA
Subject: Roof Fall Protection and OSHA Compliance
I would appreciate people's input and recommendations for best practices.
Comment from my experience: Some clients expect these services. The scope may range from installing tie-backs as part of a roof replacement to full systems for new buildings.
- To what extent is the Architect responsible for designing roof fall protection systems?
- Is the Arch responsible for designing systems to achieve OSHA compliance of the roof area?
- Are they Base Services or Expanded Services?
- Does the Arch typically include scope for their structural engineers
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James McLane AIA
Page & Turnbull
Los Angeles CA
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