Complying with OSHA’s Updated Walking-Working Surfaces Rule

walkingsurfaceimageLate last year, OSHA published new standards for walking-working surfaces and fall protection in general industry workplaces. The updated standards represent the first significant changes to the rules since OSHA first developed standards over 45 years ago. The agency’s stated goal was to “prevent and reduce workplace slips, trips, and falls, as well as other injuries and fatalities associated with walking-working surface hazards.”

According to OSHA estimates, 345 fatalities occur each year because of situations the updated rules address. In addition, employers face more than 202,000 lost-workday injuries. While the rules won’t eliminate risks, they’re expected to significantly reduce injuries and deaths, providing net benefits of more than $309 million.

The surfaces addressed by the rules include both horizontal and vertical surfaces, among them roofs, floors, ramps, elevated walkways, stairs, ladders, and scaffolding. While most new regulation inspires frustration, OSHA’s updated standards actually give employers greater flexibility in the means they use to protect workers and reflect current technology and best practices. They also create consistency with existing workplace-safety rules governing construction sites, simplifying training and supervision for contractors working in both environments.

 

Phased-in compliance

Although much of the rule went into effect on January 17, 2017, OSHA did give employers additional time to comply with many of the provisions. For example, inspections and certifications of permanent anchorages used in rope descent systems must be completed by this November 17. Employers will have until November 17, 2018 to install new fall arrest or safety systems on fixed ladders longer than 24 feet. They have an additional 18 years (until 2036) to replace any fall protection using cages and wells on ladders longer than 24 feet with personal fall arrest or ladder safety systems.

 

Flexible fall protection

OSHA’s fall protection rule applies to work surfaces at least four feet above a lower level. Additional requirements apply to specialized situations with unique hazards, such as repair pits and hoist areas.

The original rule called for guardrails as a primary safety device on elevated work surfaces, but the new standards give employers the flexibility to choose either personal fall arrest, travel restraint, or work positioning systems, depending upon which they believe is the best choice for the situation. And, in areas where fall protection measures are either impractical or needed only infrequently, employers can opt for non-conventional approaches. In addition, body harnesses must be used instead of body belts, so that fall arrest forces will be distributed over more of a worker’s body.

 

Portable ladders

The new rules require slip-resistant rungs and steps on portable ladders and specify that, when being used on surfaces that are slippery, ladders should be secured and stabilized. Top steps and caps of stepladders are not to be used, and portable ladders cannot be moved or extended when occupied by a worker. In addition, portable ladders should never be fastened together or placed on potentially unstable objects such as boxes to gain additional height.

 

Ropes and anchorages

There is now a 300-foot height limit for rope descent systems (RDS). In addition, to ensure the safety of RDS, building owners must certify that permanent anchorage points have been properly maintained, tested, and certified. Anchorages must be able to support 5,000 pounds per worker who will be attached. RDS may be used at higher elevations only if other safety systems are impractical or create more of a hazard.

 

Scaffolding and surface inspections

The new rules supplant the previous scaffolding rules with standards identical to those used in construction. Additionally, all walking-working surfaces must be inspected regularly, with any hazardous conditions corrected or repaired (or guarded against access).

 

Required training

A key element of the new rules is required training for workers in a number of high-hazard situations, including those who use personal fall protection as part of their jobs. Training delivered by a qualified person should address identifying and taking steps to reduce fall hazards, use of all fall protection systems, and how to inspect, maintain and store those systems. That training should also be repeated as needed.

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