Comment from Glucksman, Daniel; International Safety Equipment Association (ISEA)
International Safety Equipment Association (ISEA)OpposeAdvocacy
Summary: The International Safety Equipment Association (ISEA) opposes the proposed removal of the 2036 compliance deadline for retrofitting fixed ladders with personal fall arrest systems or ladder safety systems. They argue that cages and wells do not provide adequate fall protection and that the costs of modern safety systems are reasonable compared to the risk of severe injuries and fatalities.
ISEA appreciates the opportunity to submit comments on the proposed Walking-Working Surfaces rule, regarding safe climbing on fixed ladders.