OSHA's Revised Walking-Working Surfaces Standard
In the final days of 2016, OSHA finalized a revision to their Walking -Working Surfaces standard. For those not familiar, “walking-working surfaces” is the general industry term that includes hazards such as ladders and falls. For the most part, the requirements of the standard didn’t change. The main goals were to update the standard to be more flexible with fall protection options and to include performance-based language rather than strict design requirements. However, there are changes that might affect certain industries. Many of the requirements went into effect on January 18, 2017 but others have delayed effective dates which are included in the breakdown below. Here’s what’s new in the revised rule:
Fall Protection Options
- Fall protection is required in general industry anytime there’s a fall hazard of 4 feet or more. Previously, the standard was written in a way that guardrails were the only option for fall protection in general industry. The new rule expands the allowable fall protection options to include safety net systems, personal fall arrest systems, positioning systems, travel restraint systems and ladder safety systems.
Updated Scaffold Requirements
- As the scaffold requirements for general industry were quite dated, the new standard requires employers to comply with the more-current construction scaffold standard.
Rope Descent Systems (effective 11/18/2017)
- Common in certain industries such as window washing, there was nothing in the standard specific to rope descent systems; only a memorandum from 1991. The new rule adds rope descent systems as an approved way to do elevated work, adds a 300-foot height limit and requires building owners to document confirmation of verification and testing of permanent anchorages.
Qualified Climbers for Outdoor Advertising
- The previous standard included an exception that qualified climbers in outdoor advertising could climb fixed ladders on billboards without fall protection. The new rule phases this out and requires that outdoor advertising employees must follow the new fall protection phase-in timeline for fixed ladders (see Fixed Ladders section below).
Fixed Ladders That Extend More Than 24 Feet (effective dates 11/18/2018 and 11/18/2036)
- Fixed ladders are those that are permanently attached to a structure, building or equipment. The new rule begins to phase in a requirement for installation of ladder safety or personal fall arrest systems rather than the use of cages and wells:
- New fixed ladders or replacement ladders/ladder sections must have a ladder safety or personal fall arrest system installed within the next two years.
- Existing ladders must have a cage, well, ladder safety systems or personal fall arrest system installed within the next two years (if no fall protection is already installed).
- All ladders that extend more than 24 feet will need to have a ladder safety or personal fall arrest system installed within the next 20 years.
- The revised standard removes the detailed specifications and design requirement language regarding portable ladders and adds simple, performance-based language. The rules are generally the same, but they’re easier to read and understand. Some examples of the new language:
- Rungs and steps of ladders must be slip resistant.
- Portable ladders used on slippery surfaces must be secured and stabilized.
- Portable ladders can’t be moved, shifted or extended while a worker is on them.
- New to the standard, the new rule does include a requirement that employers inspect all walking-working surfaces regularly and correct, repair or guard hazards as needed.
Training (effective 5/18/2017)
- With new options for fall protection, it’s important that employees are trained on how to use these correctly. All employees who use personal fall protection must be trained on fall and equipment hazards, identification and correction of hazards, and maintenance, inspection and storage of the equipment or systems.
- If any conditions or equipment change, or an employee demonstrates a lack of knowledge, retraining must be provided.
- As with any safety training, it must be in a language and manner that the employee understands.
Questions on staying compliant? Contact us, we’re happy to help.
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