Weekly Compliance Digest – Walking-Working Surfaces, Fall Protection Systems
Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems)
What is it?
Last week, OSHA announced its long-awaited final rule updating its general industry Walking-Working Surfaces standards specific to slip, trip, and fall hazards. The rule also includes a new section under the general industry Personal Protective Equipment (PPE) standards that establishes employer requirements for using personal fall protection systems.
Falls from heights and on the same level (a working surface) are among the leading causes of serious work-related injuries and deaths. OSHA’s final rule aims to better protect workers in general industry from these hazards by updating and clarifying standards and adding training and inspection requirements.
OSHA estimates that, on average, approximately 202,066 serious (lost-workday) injuries and 345 fatalities occur annually among workers directly affected by the final standards. According to the agency, the rule will prevent 29 fatalities and 5,842 lost-workday injuries every year.
Who is affected?
The final rule affects a wide range of workers in general industry, from painters to warehouse workers. It does not change construction or agricultural standards. According to EHS Today, 112 million workers at 7 million workplaces will be impacted by OSHA’s final rule.
What are the requirements?
OSHA aligned “as much as possible” fall protection requirements for general industry with those for construction, easing compliance for employers who perform both types of activities, the agency says. For example, the final rule replaces the outdated general industry scaffold standards with a requirement that employers comply with OSHA’s construction scaffold standards.
Here are the main requirements included in the final rule:
- Fall Protection Options: Employers are required to protect workers from fall hazards along unprotected sides or edges that are at least 4 feet above a lower level. The rule sets requirements for fall protection in specific situations, such as hoist areas, runways, areas above dangerous equipment, wall openings, repair pits, stairways, and scaffolds. It also establishes requirements for the performance, inspection, use, and maintenance of personal fall protection systems. Employers can choose from the following fall protection options:
- Guardrail System
- Safety Net System
- Personal Fall Arrest System (note: the rule prohibits the use of body belts as part of a personal fall arrest system)
- Positioning System
- Travel Restraint System
- Ladder Safety System
- Rope Descent Systems: The rule permits employers to use Rope Descent Systems (RDS). However, the rule adds a 300-foot height limit for the use of RDS. 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.
- Ladder Safety Requirements: The rule includes requirements to protect workers from falling off fixed and portable ladders, as well as mobile ladder stands and platforms. Ladders must be capable of supporting their maximum intended load, while mobile ladder stands and platforms must be capable of supporting four times their maximum intended load. Each ladder must be inspected before initial use in a work shift to identify defects that could cause injury.
- Training Requirements: Employers must make sure that 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. A qualified person must train workers to correctly: identify and minimize fall hazards; use personal fall protection systems and rope descent systems; and maintain, inspect, and store equipment or systems used for fall protection.
What is next?
The final rule was published in the Federal Register on November 18, 2016, and it will be effective in 60 days, on January 17, 2017. However, 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).
- 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).
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