Comment from Callahan, Brian; Alliance for Chemical Distribution (ACD)
Alliance for Chemical Distribution (ACD)SupportTrade association
Summary: The Alliance for Chemical Distribution (ACD), representing over 400 chemical distribution companies, supports the proposed rule to remove the 2036 deadline for equipping fixed ladders with personal fall arrest systems. They argue that the deadline is arbitrary, lacks supporting data regarding ladder replacement cycles, and would impose significant and disproportionate costs on small businesses.
See attached file(s)