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OSHARulemakingOSHA-2025-0072

Walking-Working Surfaces - Fixed Ladders

RIN
1218-AD73
Last modified
Oct 13, 2026
Comment window
closed 28d ago
American Petroleum Institute filings
3

Activity

American Petroleum Institute filed 3 comments on this docket between Jun 8, 2026 and Oct 13, 2026. 19 other organizations filed here. The comment window closed 28d ago.

What American Petroleum Institute filed (3)

Oct 13, 2026· Comment from Conn, Eric; (Conn Maciel Carey LLP) on behalf of the American Fuel & Petrochemical Manufacturers (AFPM), American Petroleum Institute (API, the International Liquid Terminals Association (ILTA) and the Employers OSHA Modernization Coalition (Coalition) (AFPM - API - ILTA - Employers OSHA Modernization Coalition)· OSHA-2025-0072-0076

Filed as an attachment.

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Sep 25, 2026· Comment from Conn, Eric; (Conn Maciel Carey LLP) on behalf of American Fuel & Petrochemical Manufacturers (AFPM), American Petroleum Institute (API), International Liquid Terminals Association (ILTA), and Employers OSHA Modernization Coalition (Coalition)· OSHA-2025-0072-0072

See attached post-hearing data analysis and comments, as well as other supporting attachments.

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Jun 8, 2026· Comment from Conn, Eric (Conn Maciel Cary LLP); American Fuel & Petrochemical Manufacturers (AFPM), American Petroleum Institute (API), American Chemistry Council (ACC) and the International Liquid Terminals Association (ILTA)· OSHA-2025-0072-0043

Filed as an attachment.

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Abstract

This proposed rule is intended to provide greater compliance flexibility for employers subject to the requirements in OSHA’s Walking-Working Surfaces standard (29 CFR, Subpart D). OSHA is proposing to remove a provision that sets a deadline (November 18, 2036) for the installation of personal fall arrest systems or ladder safety systems on all fixed ladders that extend more than 24 feet above a lower level. OSHA anticipates this change will allow employers to update their ladders when the ladders reach the end of their service lives, accommodating the lengthy service life of fixed ladders while significantly reducing costs and offering greater flexibility.

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Co-filers (19)

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