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Major Changes to the Walking/Working Surfaces Standard

As you may already be aware, OSHA has begun updating the Walking/Working Surfaces standard (commonly referred to as fall protection) for general industry. This is the first update to this standard since it was adopted in 1971. OSHA has estimated that these changes will prevent 29 fatalities and 5,842 injuries from occurring annually.

Although the standard took effect on January 17, 2017, some portions such as training are being phased in at a later date. Those time frames are not based on the effective date, but rather the publication date of the final rule, which was in November 2016. This means that employers only have a couple months to implement a plan and train their employees.

What are the training requirements?
The required training is similar to that of the construction standard. Employees must be trained by a “qualified” person, and trained on recognizing hazards related to falls, minimizing those hazards, the correct procedures for installing, inspecting, operating, maintaining, and disassembling fall protection systems, and the correct use of their personal fall protection systems; such as donning, proper anchoring, connecting, etc. Employers are responsible for ensuring that any employee exposed to fall hazards are trained by May 17, 2017. Although documentation of training is not required, it would be a good practice to record at a minimum what the employee was trained on, who trained them and when it occurred. If an employee is witnessed doing something that does not coincide with the training, or if the employer feels they did not fully comprehend the training, then the employer should re-train the employee immediately.
For more information regarding training requirements, refer to the standard here:
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9722

What are the benefits on the new standard?
OSHA updated the standard to allow more flexibility for employers with respect to compliance, clarity and ease of use. The new standard incorporates parts of the construction standard, new technology, best practices, and national consensus standards. Using portions of the construction standard will also assist employers who work in other industries, such as manufacturing, distribution, and product installation.

Scaffolds
Scaffolding regulations will now be shared between both the general industry and construction standards. The previous standard was rather limited. This change will allow for more flexibility and safer conditions for employees. This standard can be found under Subpart L or the construction standard, 1926.450 through 1926.454.

Use of Ladders
Ladders, mobile ladder stands and platforms have now been combined into a single standard CFR 1910.23. Additionally, the use of ladders has been integrated into one standard. The scaffold portion of the previous “manually propelled mobile ladder stands and scaffolds (towers)” can now be found in the scaffolding standard. Fixed ladders that extend more than 24 feet will now have some phased in requirements. Any fixed ladder installed prior to November 19, 2018 must be equipped with a personal fall arrest system, ladder safety system, cage, or well. However, any fixed ladder installed after that date must have a personal fall arrest system or a ladder safety system. As you might notice from that statement, the standard does not include a cage or well; therefore, an alternate systems must be put implemented. This also include replacement, even if the alteration is only a section of the ladder, cage or well. In addition, by November 18, 2036, all fixed ladders must be converted to include a personal fall arrest system (PFAS) or a ladder safety system.

Rope Descent Systems
Rope descent systems, which are mainly used for existing building maintenance and cleaning, have been given its own designation and specific standard. Previously it was minimally address under the scaffold standard. One important item to note about this standard is that the anchor points used for fall protection must be certified in writing and kept for the duration of the job.

The standard specifically states:
“Before any rope descent system is used, the building owner must inform the employer, in writing that the building owner has identified, tested, certified, and maintained each anchorage so it is capable of supporting at least 5,000 pounds (268 kg), in any direction, for each employee attached. The information must be based on an annual inspection by a qualified person and certification of each anchorage by a qualified person, as necessary, and at least every 10 years.”

This in one of the portions of the updated standard that will be phased in, and made effective on November 20, 2017.

The rope descent system portion of the standard also requires:
• The maximum height of 300 feet when using this type of system.
• Training
• Inspections
• Independent personal fall arrest system and anchor point for each employee

If you have questions or require information on changes to the walking/working surfaces standard, contact us toll free at 1-866-273-1105. If you would like to schedule a free consultation, please complete a request form at: http://www.usfsafetyflorida.com/Consultation-Request-Form

The USF OSHA Training Institute Education Center offers safety training courses in the general, construction, and maritime industries. Visit www.usfoticenter.org to view the course schedule or to register to attend classes. Likewise, you may send an email to usfotioutreach@health.usf.edu for more information.

For additional resources on Walking/Working Surfaces:
https://www.osha.gov/walking-working-surfaces
www.osha.gov/SLTC/walkingworkingsurfaces/index.html

Fact sheet
https://www.osha.gov/Publications/OSHA3903.pdf

Q&A
https://www.osha.gov/walking-working-surfaces/faq.html

Scaffolds
https://www.osha.gov/SLTC/scaffolding/index.html
https://www.osha.gov/SLTC/etools/scaffolding/index.html

General Industry standards
https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=STANDARDS&p_toc_level=1&p_keyvalue=1910