Don’t Get Tripped Up by OSHA’s Walking-Working Surfaces Standard

Rayaz Qureshi-Chishti, J.J. Keller

OSHA’s efforts to address slips, trips and fall hazards in General Industry began in 1971, when it created 1910 Subpart D, “Walking-Working Surfaces.” Since that time, efforts to revise these requirements have been ongoing, including proposed rules issued in 1973, 1990 and 2010. The most recent proposal, finalized in 2016, impacted all general industry employers and affects more than 100 million employees.

The changes to Subpart D were a significant overhaul of the requirements and include new technology and industry methods intended to reduce the number of fall-related employee deaths and injuries. The majority of employees in general industry workplaces walk or work on surfaces where slips, trips and falls are common. This includes floors, aisles, stairs, ladders, platforms, roofs, etc.

The standard focuses on proactive safety management, meaning that OSHA expects employers to find and fix workplace hazards before they become an issue. OSHA says exposure to these types of hazards pose a “significant risk” of death or serious harm to workers.

What is a Walking-Working Surface?

They are surfaces like floors, aisles, stairs, ladders, roofs, platforms, dockboards and more. When you identify walking-working surface hazards, you must take proactive measures, such as use of fall protection, to eliminate those hazards. Fall protection includes using: covers, designated areas, guardrails, handrails, personal fall protection systems, ladder safety systems and safety nets.

The standard requires employers to conduct regular inspections to identify and mitigate slip, trip and fall hazards. Things to keep in mind while performing these inspections include:

  • Passageways, storerooms, service rooms and walking-working surfaces must be kept clean, orderly and sanitary;
  • Walking-working surfaces must have a proper load rating to safely support loads applied to them;
  • If a corrective action or repair cannot be made immediately, the hazard must be guarded to prevent employees from using the walking-working surface;
  • False floors, platforms and mats must be provided when wet processes are used;
  • Workroom floors must be kept clean and dry;
  • Hazardous conditions on walking-working surfaces must be corrected or repaired before an employee can work there again;
  • Employers must provide safe access and egress to and from walking-working surfaces;
  • Protruding objects, loose boards, corrosion, leaks, spills, snow and ice are not allowed on walking-working surfaces; and
  • Only a qualified person can repair structural integrity issues on a walking-working surface.

Walking-Working Surfaces Rule’s Major Changes

Fall protection flexibility (1910.28(b)): The final rule allows employers to protect workers from falls by choosing from a range of accepted fall protection systems, including personal fall protection systems. It eliminates the existing mandate to use guardrails as the primary fall protection method and gives employers the flexibility to determine what method they believe will work best in their particular workplace situation. This approach has been successful in the construction industry since 1994. The final rule allows employers to use non-conventional fall protection practices in certain situations, such as designated areas on low-slope roofs for work that is temporary and infrequent and fall protection plans on residential roofs when employers demonstrate guardrail, safety net or personal fall protection systems are not feasible or create a greater hazard (1910.28(b)(1) and (b)(13));

Updated scaffold requirements (1910.27(a)): The final rule replaces the outdated general industry scaffold standards with the requirement that employers comply with OSHA’s construction scaffold standards;

Phase-in of ladder safety systems or personal fall arrest systems on fixed ladders (1910.28(b)(9)): The final rule phases in over 20 years a requirement to equip fixed ladders (that extend over 24ft) 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 of November 18, 2036. There is wide recognition that cages and wells do not prevent workers from falling from fixed ladders or protect them from injury if a fall occurs. The final rule grandfathers in cages and wells on existing ladders, but requires during the phase-in period that employers equip new ladders and replacement ladders/ladder sections with ladder safety or personal fall arrest systems;

Phase-out of the “qualified climber” exception in outdoor advertising (1910.28(b)(10)): The final rule phases out OSHA’s directive allowing qualified climbers in outdoor advertising to climb fixed ladders on billboards without fall protection and phases in the requirement to equip fixed ladders (over 24ft) with ladder safety or personal fall arrest systems. Outdoor advertising employers must follow the fall protection phase-in timeline for fixed ladders. However, if ladders do not have any fall protection, outdoor advertising employers have until November 19, 2018, to comply with the existing standard (i.e., install a cage or well) or, instead, they may install a ladder safety or personal fall arrest system, both of which are cheaper than cages or wells;

Rope descent systems (RDS) and certification of anchorages (1910.27(b)): The final rule codifies OSHA’s memorandum for employers who use RDS to perform elevated work. The final rule prohibits employers from using RDS at heights greater than 300ft above grade, unless they demonstrate it is not feasible or creates a greater hazard to use any other system above that height. In addition, the final rule requires building owners to provide and employers to obtain information 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.

Personal fall protection system performance and use requirements (1910.140): The final rule, which allows employers to use personal fall protection systems (i.e., personal fall arrest, travel restraint, and positioning systems), adds requirements on the performance, inspection, use, and maintenance of these systems. Like OSHA’s construction standards, the final rule prohibits the use of body belts as part of a personal fall arrest system;

Inspection of walking-working surfaces (1910.22(d)): The final rule requires that employers inspect walking-working surfaces regularly and as needed and correct, repair or guard against hazardous conditions; and

Training (1910.30): The final rule adds requirements that employers ensure workers who use personal fall protection and work in other specified high hazard situations are trained, and retrained as necessary, about fall and equipment hazards, including fall protection systems. Employers must provide information and training to each worker in a manner the worker understands.

Walking-working surface timeline

Most of the rule became effective January 17, 2017, 60 days after it was published in the Federal Register on November 18, 2016, but some provisions had delayed effective dates, including:

  • Ensuring exposed workers are trained on fall hazards (May 17, 2017),
  • Ensuring workers who use equipment covered by the final rule are trained (May 17, 2017),
  • Inspecting and certifying permanent anchorages for rope descent systems (November 20, 2017),
  • Installing personal fall arrest or ladder safety systems on new fixed ladders over 24ft and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures (November 19, 2018),
  • Ensuring existing fixed ladders over 24ft, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system or ladder safety system (November 19, 2018), and
  • Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24ft (November 18, 2036). PS

About the author:

Ray Chishti joined J. J. Keller in 2017 as a Workplace Safety Editor. He has 11 years of ES&H experience in a variety of industries, including EPC projects, fossil fuel power plants, gas distribution and transmission, and electrical transmission work. Ray’s experience also include an additional four years of EH&S experience in retail grocery stores and warehouse facilities, as well as construction of a college campus. Ray’s areas of expertise include OSHA safety and environmental safety/compliance. Before joining J. J. Keller, Ray served as an EH&S professional, both in auditing and leadership positions with new construction, existing facilities, and large EPC projects valued between one million and two billion dollars.