Summary of Caged Ladder Statements in 29 CFR Pt 1910 Subpt D
This is a summary of the statements regarding caged ladders and fall-arrest systems for fixed ladders, found in U.S. legislation 29 CFR Pt 1910 Subpt D, as published earlier this year.
P.3 (Ladder safety system clause): “Cages and wells are not ladder safety systems.”
DR comment: this is a downgrading of cages – they no longer have fall protection/safety status.
P.34 (Fixed ladders that extend more than 7.3 m above a lower level):
“The Employer must ensure:
Existing fixed ladders: Each fixed ladder installed before Nov 19, 2018 is equipped with a personal fall arrest system, ladder safety system, cage or well.
New fixed ladders: Each fixed ladder installed on and after Nov 19, 2018 is equipped with a personal fall arrest system or a ladder safety system.
Replacement: When a fixed ladder, cage, or well, or any portion of a section thereof is replaced, a personal fall arrest system or ladder safety system is installed in at least that section of the fixed ladder, cage or well where the replacement is located.
Final deadline: On and after Nov 18, 2036, all fixed ladders are equipped with a personal fall arrest system or ladder safety system.”
DR comment: if a ladder was installed before Nov 2018 there is no change. Employers can use a cage or personal fall-arrest/ladder safety system.
Any new ladder installed after Nov 2018 has to have a personal fall-arrest/ladder safety system installed, irrespective if there is a cage or not. Purely from a cost perspective, it is unlikely that cages will continue to be installed.
When a ladder and/or cage or a part of a ladder/cage is replaced, a personal fall-arrest/ladder safety system has to be installed in at least the replaced section. No date guidance.
After Nov 2036, every fixed ladder, whether with a cage or not, has to have a or personal fall-arrest/ladder safety system installed.
P.35 (clause iv):
“The employer may use a cage or well in combination with a personal fall arrest system or ladder safety system provided that the cage or well does not interfere with the operation of the system”.
DR Comment: although not introducing an outright ban on cages, it’s clear that cages cannot be relied upon to provide positive fall protection on their own, so they’ll need to have a fall arrest system installed. A fall simulation test will have to be devised to demonstrate that cages do not interfere with the operation of the particular fall-arrest system.