OSHA Walking Working Surfaces: Don't Get Tripped Up!
Each year over 200,000 employees are injured and hundreds die from falls from heights and falls to the same level. OSHA’s final rule on Walking Working Surfaces and Personal Fall Protection focuses on better protecting employees from these hazards.
The final rule became effective on January 17, 2017, updating the general industry standards addressing slip, trip and fall hazards (§1910 Subpart D) and adding requirements for personal fall protection systems (§1910 Subpart I). Many of these updates better align general industry with construction standards. Even though the updated standard has been in place for more than two years, many employers have questions or even remain unaware of the changes.
An important change that may affect your workplace pertains to guardrails. Previously, guardrails had been required as the primary fall protection method for open sides or edges 4’ or higher. With the new performance-based rule, employers may decide which acceptable fall protection system best fits an individual situation; providing the employer with greater compliance flexibility. For example, edge proximity restrictions may be used on low-slope roofs that are temporarily and infrequently accessed.
NOTE: In the example above, employers must be able to demonstrate that guardrails, safety nets, or personal fall protection systems are not feasible or create a greater hazard (§1910.28(b)(1) and (b)(13)).
For window washers and other exterior building maintenance personnel, the final rule prohibits employers from using rope descent systems (RDS) at heights greater than 300 feet (certain exceptions apply). In addition, building owners must provide, and employers must obtain, proof that permanent anchorages used with RDS have been inspected, tested, certified, and maintained as capable of supporting at least 5,000 pounds per employee attached. (§1910.27(b))
Specific employer requirements include:
- Train workers on how to use fall protection systems, including performance, use and maintenance.
- Train exposed workers on fall hazards.
- Inspect walking-working surfaces regularly and as needed. Correct, repair, or guard against hazardous conditions.
- Install fall protection (personal fall arrest systems, ladder safety systems, cages, wells) on existing fixed ladders (over 24 feet) that do not have any fall protection.
- Install ladder safety or personal fall arrest systems on new fixed ladders (over 24 feet) and replacement ladders.
Note: Over the next 20 years, the rule phases in a requirement to equip fixed ladders (which extend over 24 feet) with ladder safety or personal fall arrest systems and prohibits the use of cages and wells as a means of fall protection after the phase-in deadline. (§1910.28(b)(9))
The training requirements of the rule are performance-based, which allows employers to choose the methods of training. Employers may use classroom, audio-visual, demonstrations, field training, web-based, computer-based or other forms of training to meet the requirements of the standard. Regardless of the method, training must be performed by a qualified person (1910.30(a) (2)), and if web, video, or computer-based methods are used, a qualified person must be available to answer questions.
Retraining is also performance-based and required as needed. “As needed” can be interpreted as following an incident, near miss, process change, or equipment change. There is no annual training requirement.
With the implementation of the final standard, OSHA estimates that 29 fatalities and more than 5,842 lost-workday injuries will be avoided annually. With that impact it may well be worth the 25 years of work that went into the development and implementation of this standard. Falls are the leading cause of traumatic brain injuries.
By Randy Morehouse