OSHA Finally Issues Walking-Working Surfaces Rule

By Nickole C. Winnett © Jackson Lewis Dec 6, 2016

On Nov. 17, OSHA issued a final rule revising and updating its general industry walking-working surfaces standards specific to slip, trip and fall hazards. The final rule includes revised and new provisions addressing fixed ladders, rope descent systems and fall protection systems.

The rule also establishes requirements on the design, performance and use of personal fall protection systems in general industry. In addition, employers must now train employees on identifying and minimizing fall hazards, using fall protection systems, and maintaining, inspecting and storing fall protection equipment.

The final rule allows employers to select the fall protection system that works best for their environment instead of requiring the use of guardrail systems, which the current rule mandates.

Employers now can choose from a range of accepted options, including personal fall arrest, safety new system, ladder safety systems, travel restraint and work position systems.

OSHA has permitted the use of personal fall protection systems in construction since 1994, and the final rule adopts similar requirements for general industry.

The final rule codifies a 1991 OSHA memorandum that permits employers to use rope descent systems (RDS) and adds a 300-foot height limit for their use. It also requires building owners to affirm in writing that permanent building anchorages used for RDS have been tested, certified and maintained as capable of supporting 5,000 pounds for each worker attached.

The final rule also requires that ladders be capable of supporting their maximum intended load and that mobile ladder stands and platforms be capable of supporting four times their maximum intended load.

Moreover, each ladder must be inspected before initial use in a work shift to identify defects that could cause injury.

For fixed ladders that extend more than 24 feet, the rule phases in ladder safety or personal fall arrest systems and phases out the use of cages or wells. For portal ladders, employers must ensure that rungs and steps are slip resistant; portable ladders used on slippery surfaces are secured and stabilized; portable ladders are not moved, shifted or extended while a worker is on them; top steps and caps of stepladders are not used as steps; ladders are not fastened together to provide added length unless designed for such use; and ladders are not placed on boxes, barrels or other unstable bases to obtain added height.

OSHA drew from requirements in the national consensus standards in crafting the new rule, including ANSI/ASSE A1264.1–2007, Safety Requirements for Workplace Walking/Working Surfaces and Their Access; Workplace, Floor, Wall and Roof Openings; Stairs and Guardrail Systems; ANSI/ASSE Z359.1–2007, Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components; and ANSI/IWCA I–14.1–2001, Window Cleaning Safety Standard.

OSHA anticipates that the changes provided in the final rule will prevent 29 fatalities and 5,842 lost-workday injuries annually.

Timeline

The final rule becomes effective on Jan. 17, 2017. Some requirements in the new rule have compliance dates after the effective date including:

  • Ensuring exposed workers are trained on fall hazards and the use of fall protection equipment (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).
  • 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).

Nickole C. Winnett is an attorney with Jackson Lewis in Washington, D.C. © Jackson Lewis. All rights reserved. Reposted with permission. 

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