FPA Supports a Proposed Rule to Amend OSHA’s Walking Working Surfaces Standards by Repealing Compliance Deadline for Implementing Personal Fall Arrest Systems by Nov. 18, 2036, for All Fixed Tall Ladders Over 24 Feet

The Flexible Packaging Association (FPA), the national organization representing U.S. manufacturers of flexible packaging, supports OSHA’s April 6, 2026, proposal to remove the deadline for replacing fixed ladders that extend more than 24 feet from a lower level and implementing them with personal fall arrest or ladder safety systems by Nov. 18, 2036. Since the 2016 rule was published, ladder safety systems have been installed and/or replaced in flexible packaging plants at the end of an affected ladder’s useful life. FPA wants to underscore, however, that as of spring 2026, companies have replaced less than a quarter of the tall fixed ladders in their facilities because of the typically long service lives of the “affected ladders” and because of the cost of replacing them. For this reason, FPA believes it is reasonable to “repeal” the 2036 compliance date at 29 CFR 910.28(b)(9)(i)(D), as proposed in the April 6th, 2026 Notice of Proposed Rulemaking (“NPRM” or “Notice”).