OSHA’s Updated Walking-Working Surfaces Ruling

From time to time, we think a bit outside the box and post articles that go beyond sharing technical information about Unistrut products and applications.

Today’s post borrows on information we’ve published on our sister company’s blog–Diversified Fall Protection–and the topic is OSHA’s updated ruling on slips, trips, and falls.  Whether you are an engineer, architect, general contractor, facilities manager, or work in some other related field, chances are good, you’ll have folks asking about OSHA’s new ruling.

ladder-with-cage-and-wellOn November 18, 2016 the Occupational Safety and Health Administration issued its final ruling on Walking-Working Surfaces (29 CFR Part 1910, Subpart D) and the general industry Personal Protective Equipment Standards (29 CFR Part 1910, Subpart I). The revised ruling will impact 112.3 million employees at 6.9 million general industry establishments. With many of the provisions of the final ruling scheduled to become effective early next year, many are wondering about the steps their companies need to take to ensure compliance.

The final applies to all general industry walking-working surfaces such as floors, ladders, stairways, dockboards, scaffolds, roofs, elevated work surfaces, and walkways and includes revised and new language covering fixed ladders, rope descent systems, fall protection systems and criteria, including personal fall protection systems, and training on fall hazards and fall protection systems.

One of the most referenced sections of the new ruling is the portion granting employers greater flexibility to determine the fall protection system which is best suited for their application. Unlike the prior, guardrail-centric, Working-Walking Surfaces ruling, OSHA now allows employers to protect workers from falling to lower levels via use of personal fall protection and fall arrest systems, travel restraint, and work positioning systems.  In addition, OSHA has a host of additional requirements that are become effective in January, 2017, and beyond, including:

  • The identification and evaluation of slip, trip, and fall hazards and the providing of appropriate personal protective equipment to protect workers from said hazards (Subpart I, Personal Protective Equipment)
  • Conducting and documenting regular and periodic inspections and maintenance of all workplace walking-working surfaces
  • Providing training to help employees to identify fall hazards and the procedures to be followed to minimize said hazards (e.g., use of personal fall protection, proper ladder climbing techniques, etc.)
  • The eventual phasing out of ladder cages as an OSHA-approved form of fall protection for fixed ladder systems

Out of all these new provisions, the revised fixed ladder regulations may have the most sweeping consequences since we see so many ladders equipped with cages and wells.

Timetable for Compliance
The final rule is effective on January 17, 2017, but some provisions have delayed effective dates, including:

  • Ensuring exposed workers are trained on fall hazards (6 months),
  • Ensuring workers who use equipment covered by the final rule are trained (6 months),
  • Inspecting and certifying permanent anchorages for rope descent systems (1 year),
  • Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures (2 years),
  • Ensuring existing fixed ladders over 24 feet, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system (2 years), and,
  • Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet (20 years).

Attempts to revise the Walking-Working Surfaces ruling have been decades in the making, and this initiative is the most sweeping change to General Industry regulations since OSHA’s inception in 1971.  What’s more, one post here doesn’t do full justice to all of the changes that are on the horizon as a result of this new ruling.  We’ll break down specific provisions of the new regulations in future Tech Talk posts, so be sure to check back for new articles in the months ahead.  In the meantime, if you have questions, or need to speak with us to determine how the new ruling may impact your safety program or facilities, contact Unistrut Service Company for further assistance.

Helpful Links:
Text of OSHA’s Updated Walking-Working Surfaces Ruling
OSHA Walking Working Surfaces Fact Sheet