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)

Summary: Conn Maciel Carey LLP, representing members of the AFPM, API, and ACC, opposes the proposed rule requiring fall arrest systems (FAS) on ladders in cages and wells. They argue that FAS are less effective than existing cages, create new safety hazards (such as entanglement and ergonomic stress), and impose exorbitant costs on the refining industry.