Pop quiz: What’s the most commonly cited OSHA violation, year after year?
If you said falls, congratulations – you know a thing or two about safety violations. Hopefully, you know it from the statistics and haven't experienced one personally. But even if you've managed to avoid work-related falls, chances are you know someone who hasn't been so lucky.
Fall protection has held the top spot in OSHA's most frequently cited safety violations for 12 years running. This article will go over some of the things you need to know in order to avoid violating this important standard, including some clarifications over the "walking-working surface" rule.
What Is OSHA Doing to Protect Workers from Falls?
To protect all general industry workers, OSHA issued a final rule on walking-working surfaces to update the existing standards they had set over the last five decades. With this update, OSHA plans to prevent 29 fall-related fatalities a year, along with 5,842 lost work injuries.
This final rule updates the general industry standard for slip, trip, and fall hazards (Subpart D) and adds requirements for personal fall protection systems (Subpart 1). It also aims to make compliance easier and less expensive by harmonizing the general industry requirements with those for the construction industry, as well as many American National Standards Institute (ANSI) standards.
For example, the final rule eliminates the previous mandate to use guardrails as a primary fall protection method. Instead, employers can now choose the accepted fall protection system they believe will work best for a particular situation, a method the construction industry has been using since 1994.
Timeline of the Walking-Working Surface Rule
The final rule came into effect on January 17, 2017 – 60 days after publication in the Federal Register. However, several requirements laid out in the final rule include compliance dates that began on May 17, 2017.
The dates for the Subpart D Section are as follows:
- May 17, 2017 – Train workers on fall and equipment hazards
- November 20, 2017 – Inspection and certification of permanent building anchorages
- November 19, 2018 – Installation of fall protection (personal fall arrest systems, ladder safety systems, cages, wells) on existing fixed ladders over 24 feet that don’t have fall protection
- November 19, 2018 – Installation of ladder safety or personal fall arrest systems on new fixed ladders over 24 feet and replacement ladders and ladder sections
- November 18, 2036 – Installation of ladder safety systems or personal fall arrest systems on all fixed ladders over 24 feet
(Find out How to Choose Your Fall Protection Anchorage)
Who Is Protected Under the Walking-Working Final Rule?
The new rule applies to all general industry workers and includes horizontal, vertical, and inclined surfaces, such as:
- Floors
- Stairs
- Roofs
- Ladders
- Ramps
- Scaffolds
- Elevated walkways
- Fall protection systems
Workers in general industry include, among many others:
- Building management services
- Roofers
- Utility workers
- Chimney sweeps
Note, however, that OSHA added a provision in the final rule for residential roofers to increase consistency between the general industry and construction standards. This is meant to make it easier to perform both types of activities on residential roofs.
How Will This Final Rule Keep Your Employees Safe?
The final rule introduces a number of measures to protect workers from falls, including:
- Phasing out the use of qualified climbers in outdoor advertising (to eliminate the hazard of workers climbing extended heights on fixed ladders without fall protection)
- Phasing in a requirement that fixed ladders (over 24 feet) must be equipped with ladder safety or personal fall protection systems (to prevent workers from falling, or arresting their fall before contract with a lower level)
- Providing performance criteria for personal fall protection equipment in general industry (similar to OSHA’s construction industry rules)
- Requiring the use of body harnesses and prohibiting body belts in personal fall arrest systems to distribute fall arrest forces over a larger area of a worker’s body
- Requiring workers who use fall protection equipment to be trained in its use before working at heights
Employer Responsibilities Under the Final Rule
Since the implementation of the final rule, employers have had to update their fall protection programs to conform with a number of changes, including:
- Replacing fixed ladder cages and wells with personal fall arrest systems or ladder safety systems
- Only using rope decent systems for heights under 300 feet above grade
- Documenting and providing proof that the permanent anchorage used with a rope descent system has been inspected, tested, certified, maintained, and can support at least 5,000 lbs. per employee attached.
- Inspecting walking-working surfaces regularly and ensuring no hazardous conditions exist
- Using fall protection carabiners, D-rings, and snap hooks that have been proof-tested for tensile loads of 3,600 lbs., aligning with ANSI ASSE z359.
- Ensuring that all users are trained by a qualified person (as per OSHA 1910.30) in the proper installation, use, inspection, and maintenance of fall protection equipment
How Employers Benefit from the Final Rule
While the final rule is focused on keeping workers safe, it has a number of benefits for their employers as well. For instance:
- Greater flexibility to choose from an increased array of fall protection options
- Greater consistency between general industry and construction standards, allowing for more effective and cost-efficient protection measures
- Greater ease in following and understanding the rule, thanks to performance-based language and criteria
Create a Safer Workplace Now
Protect your workers by implementing these changes now! You have the power to create a safer workforce for your employees, so more workers go home safely.
Still have questions about the final rule on walking-working surfaces? Consult this FAQ on OSHA's site for additional information.