The updated PIP standard is actually than OSHA in one way: it requires a PFAS even if the ladder is only 22 feet but located in an area with overhead crane traffic (increased fall risk due to vibration).
As of April 2026, a major shift has occurred in the industry. OSHA has proposed removing the original for retrofitting all existing caged ladders. Fall Protection Requirements for Fixed Ladders - OSHA pip stf05501 fixed ladders and cages updated