Late Comment from Thornton, Dalia; American Federation of State, County and Municipal Employees’ (AFSCME)

Summary: The American Federation of State, County and Municipal Employees (AFSCME) opposes the proposed rule because it would remove the 2036 compliance deadline for installing fall prevention systems on fixed ladders over 24 feet high. The union argues that existing caged ladders provide no protection against severe injury or death and that the 2036 deadline is necessary to give employers sufficient time to implement modern safety technology.