IHMM Files Comments on OSHA Walking-Working Proposed Rule, Effects on CSHMs, CSMPs, CHMMs, CHMPs

IHMM Comments

Federal Register

OSHA’s April 6, 2026, proposed rule would amend the Walking-Working Surfaces standard by removing the November 18, 2036 deadline requiring existing fixed ladders extending more than 24 feet above a lower level to be retrofitted with personal fall arrest or ladder safety systems, while retaining the requirement that new fixed ladders be equipped with such systems. OSHA frames the proposal as a cost-saving and flexibility measure, allowing employers to upgrade ladders at the end of their service lives.

IHMM’s comments recognize OSHA’s authority to modernize standards but urge the agency to ensure that regulatory flexibility does not dilute worker protection. Falls remain among the most serious workplace hazards, and OSHA’s walking-working surfaces standards are intended to reduce deaths and injuries from slips, trips, and falls. IHMM’s position is that any final rule should preserve enforceable safety expectations, require competent hazard assessment, encourage documented inspection and training programs, and recognize the practical role of qualified credential holders.

IHMM emphasized four credentials: CSHM, CSMP, CHMM, and CHMP. CSHMs and CSMPs are directly engaged in workplace safety systems, fall prevention, inspections, and compliance management. CHMMs and CHMPs are critical where fixed ladders, elevated work, tanks, process areas, hazardous materials, and emergency conditions intersect.