Toolbox Talk · Ladders & Climbing · English
Migna Safety Solutions
Fixed Ladders and the 2036 Deadline
About 8 minutes to deliver · 29 CFR 1910.23 · 29 CFR 1910.28
A cage on a fixed ladder looks like fall protection. It is not, and it never was — it keeps a falling person roughly in line with the ladder while they fall the whole way down. OSHA said so in the 2016 walking-working surfaces rule and put dates on fixing it.
The numbers
1910.28(b)(9)(i) applies to fixed ladders extending more than 24 feet above a lower level:
- Ladders installed before 19 November 2018 may have a personal fall arrest system, a ladder safety system, a cage, or a well.
- Ladders installed on or after 19 November 2018 must have a personal fall arrest system or a ladder safety system. A cage no longer counts on a new ladder.
- When a ladder, cage or well is replaced, in whole or in part, a personal fall arrest system or ladder safety system goes into at least that section.
- On and after 18 November 2036, every fixed ladder over 24 feet must have a personal fall arrest system or a ladder safety system. No exceptions, no grandfathering.
If your building has a caged ladder to a roof, a tank, a silo or a mezzanine, that is a dated obligation, and 2036 arrives one replacement at a time.
What a ladder safety system is
A carrier — a rail or a cable running the length of the ladder — with a sleeve or trolley that travels with you and locks when it moves fast. You wear a harness and connect to the sleeve at the bottom, climb, and disconnect at the top. It stops a fall in inches.
That is a different thing from a cage, and it is what the deadline is about.
Climbing one
- Three points of contact, face the ladder, and nothing in your hands.
- Connect before you leave the ground and disconnect only when you are on the landing, past the rail.
- Check the sleeve travels and locks before you commit to the climb.
- Look at the ladder. Corroded rungs, loose brackets, missing bolts, a rung worn thin at the middle. A fixed ladder outdoors rusts from the inside of the bracket where you cannot see it — report anything that moves.
- Landings and extensions. The rails have to extend 42 inches above the landing, or there has to be a grab bar. Getting off the top is where people fall.
The everyday one
Nobody climbs a fixed ladder carrying anything. Hoist it, wear a bag, or make two trips — on a 30-foot ladder there is nowhere to put it down and nothing to catch you.
Ask the crew
- Do we have fixed ladders over 24 feet, and what is on them — a cage or a system?
- Has anyone climbed one carrying something this week?
- Which of our ladders is due for replacement, and does anyone know the rule applies then?
This is a toolbox talk, not a course. It is general awareness on one topic — not site-specific, not a hazard assessment, and not a substitute for assessment of your workplace by a competent person, your written programs, or manufacturers’ instructions. It does not by itself satisfy any OSHA training requirement. Regulations change; verify against the current standard. Whoever delivers it is responsible for deciding it is suitable and sufficient for the work. Where a talk covers first aid, resuscitation, or mental health it is general safety information, not medical advice, not a substitute for professional medical care or certified emergency-response training, and it confers no certification — in an emergency, call 911. Free to print and use, as is, with no warranty of any kind. Migna Safety Solutions · training.mignasafetysolutions.com
Attendance Record
Form supplied by Migna Safety Solutions
Fixed Ladders and the 2036 Deadline
29 CFR 1910.23 · 29 CFR 1910.28
I delivered this talk and determined it was suitable for this crew and this work.
| # | Print name | Signature | Date |
|---|---|---|---|
| 1 | |||
| 2 | |||
| 3 | |||
| 4 | |||
| 5 | |||
| 6 | |||
| 7 | |||
| 8 | |||
| 9 | |||
| 10 | |||
| 11 | |||
| 12 | |||
| 13 | |||
| 14 | |||
| 15 | |||
| 16 | |||
| 17 |
Keep this sheet with your training records. This form is supplied blank by Migna Safety Solutions — we did not deliver this session, were not present, and make no representation about what was said or who attended. A toolbox talk is general awareness on one topic and does not by itself satisfy any OSHA training requirement. The employer remains responsible for site-specific hazard assessment and for the training its workers are required to have. Where a talk covers first aid, resuscitation, or mental health it is general safety information, not medical advice, and confers no certification — in an emergency, call 911. Free to print and use, as is, with no warranty of any kind. training.mignasafetysolutions.com