Walking-Working Surfaces and Fall Protection Standards: Update to the General Industry Standards

Matt OlphinRisk Management

Beginning in 1971, the Occupational Safety and Health Administration’s (OSHA) first issued 29 CFR 1910 Subpart D, “Walking-Working Surfaces” to help prevent injuries and fatalities resulting from slip, trip, and fall type exposures. Many efforts have been made to update the standard since 1971, and many believe the standard is outdated and does not reflect current technologies available to prevent these types of injuries and fatalities.

Falls from heights and on the same level (a working surface) are among the leading causes of serious work-related injuries and deaths. OSHA estimates that, on average, approximately 202,066 serious (lost-workday) injuries and 345 fatalities occur annually among workers directly affected by the final standard. OSHA has issued a final rule on Walking-Working Surfaces and Personal Fall Protection Systems to better protect workers in general industry from these hazards by updating and clarifying standards and adding training and inspection requirements.

Essentially, the new rule is a complete overhaul of the old rule and when the old rule is compared to the new rule – very few of the sections match up and several are new with new requirements. The rule incorporates advances in technology, industry best practices, and national consensus standards to provide what is hopefully more effective and cost-efficient worker protection. OSHA estimates this rule will prevent 29 fatalities and 5,842 lost-workday injuries every year.

The rule benefits employers by providing greater flexibility in choosing a fall protection system. For example, it eliminates the existing mandate to use guardrails as a primary fall protection method and allows employers to choose from accepted fall protection systems they believe will work best in a particular situation — an approach that has been successful in the construction industry since 1994. In addition, employers will be able to use nonconventional fall protection in certain situations, such as designated areas on low-slope roofs. Where possible, OSHA aligned these General Industry requirements with the Construction Fall Protection requirements. As an example, the old General Industry requirements for scaffolds were deleted, and the new requirements simply state: Scaffolds used in general industry must meet the requirements in 29 CFR part 1926, subpart L (Scaffolds). This is a specific reference to the Construction Industry scaffold safety requirements.

Some of the highlights from the new rule:

  • The ability for employers to choose appropriate fall protection options such as: guardrails, safety nets, personal fall arrest, positioning system, travel restraint, and/or ladder safety system.
  • Requires any company doing General Industry work to comply with these requirements. Meaning contractors or trades related companies doing General Industry work, such as maintenance, will need to comply with these requirements as well.
  • Defines specific requirements for doing inspections of equipment such as ladders and rope descent systems.
  • Provides design specifications for step bolts, manhole steps, stairways, ladders, dockboards, rope descent systems, and more.
  • Dictates the duty to have fall protection in many different areas such as unprotected sides and edges, working around dangerous equipment and pits, outdoor advertising, ramps, and low slope roofs – just to name a few.

Timeline for Compliance

The new standard was published November 18, 2016 in the Federal Register and became effective 60 days afterward = January 17, 2017. There are several parts of the new rule that do not become effective until either 6 months later to 1-2 years later to even 20 years into the future. An example of some of these are below.

If you have questions, contact

Matt Olphin, CSP, ARM, Vice President, Risk Control Services at molphin@murrayins.com

or Deb Franklin, Vice President, HR Solutions, at dfranklin@murrayins.com.


Share this Post