What: On April 10, 2025, the Consumer Product Safety Commission (CPSC) published a request for comments on whether the CPSC should establish a regulation for child-resistant above-ground and portable pool ladders.
On January 22, 2025, a petition was submitted requesting that the CPSC establish a mandatory regulation for child-resistant above-ground and portable pool ladders to reduce the drowning deaths of children younger than 5 years of age, and particularly children between 1 and 3 years, the age group asserted to be at greatest risk.
Why: The petition notes that two voluntary standards are relevant to this petition: (1) ASTM Standard Specification for Aboveground Portable Pools for Residential Use, ASTM F2666-16; and (2) ANSI/APSP/ICC-4 2012 American National Standard for Aboveground/Onground Residential Pools. ASTM F2666-16 covers all types of portable pools with a water depth of less than 36 inches (91 cm). ANSI/APSP-4 pertains to aboveground/on ground residential swimming pools with a water depth of 36 inches (91 cm) or greater. However, the petition states there is no protocol or metric required to verify that a ladder is child resistant. Rather, ASTM F2-666-16 states, “Verification can be satisfied by document review.” The petition also asserts that above-ground pools (having a side height measuring at least 36 inches) are much more likely to be involved in child drownings than portable pools.
The petition asserts, based on a review and analysis of the CPSC In-Depth Investigations and CPSC data regarding nonfatal drowning injuries and deaths related to pools, that child-resistant ladders are necessary to mitigate the risk of drowning from children’s access to above-ground and portable pools. Therefore, the petition requests that the CPSC develop a regulation that will require child-resistance for all pool ladders sold with, or for, above-ground or portable pools to mitigate the risk of drowning. Specifically, the petition requests the CPSC promulgate a mandatory regulation to establish: (1) a child-resistance requirement for A-frame and other ladders intended for above-ground and portable pools and (2) an objective and measurable definition of “child-resistant.”
The CPSC seeks comment from the public concerning this petition and any studies or data pertaining to child-resistance for ladders intended to be used with above-ground and portable pools. To the extent possible, commenters should provide specific information, including reference to known documentation, engineering studies, technical studies, reports of injuries, medical findings, legal analyses, economic analyses, and environmental impact analyses.
Action: Comments are due by June 9, 2025.
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