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Under old Subpart D, fixed ladders of more than 20 feet, to a maximum unbroken length of 30 feet, had to have a cage or well as the required means of fall protection. OSHA says, however, there is wide recognition that cages and wells neither prevent workers from falling off ladders nor protect them from injury when a fall occurs. Cages and wells simply contain employees in the event of a fall and direct them to a lower landing. For this reason, OSHA is phasing out the use of cages and wells as fall protection on fixed ladders.
By November 18, 2036, all fixed ladders that extend more than 24 feet above a lower level must be equipped with a ladder safety system or personal fall arrest system per 1910.23(b)(9)(D). This means that some existing fixed ladders will have to be replaced to meet this new requirement. Fixed ladders that have a cage or well, but not a ladder safety system or personal fall arrest system, can be used until either the ladder, cage, or well (or a portion of it) is replaced or November 18, 2036, whichever comes first.