Knowing the new rule requirements can help you keep your walking working surfaces and equipment safer for your workers.

Walking Working Surfaces: OSHA’s New Final Rule

The Workplace Today Regulation

Knowing the new rule requirements can help you keep your walking working surfaces and equipment safer for your workers.

OSHA published the Walking Working Surfaces (29 CFR 1910, Subpart D) and Personal Protective Equipment (29 CFR 1910 Subpart I)/Fall Protection Systems final rule on November 18, 2016. The agency revised and updated these general industry standards “to prevent and reduce workplace slips, trips, and falls, as well as other injuries and fatalities associated with walking-working surface hazards.”

Goals for OSHA’s New Final Rule

One of OSHA’s goals with this new rule is to increase consistency between the general industry and construction standards, which the agency says will make compliance easier for employers who conduct operations in both industry sectors. Other reasons cited by the agency for the changes are to update the requirements to mirror advances in technology; to harmonize them with updated OSHA standards and national consensus standards; and to use performance-based language to give employers greater flexibility in the implementation of their regulations.

OSHA estimates that approximately 202,066 lost-workday injuries and 345 fatalities occur every year among workers impacted by the final standard, and that the new rule will prevent 5,842 of these lost-workday injuries and 29 of these fatalities annually.

One improvement cited by OSHA is that the new rule offers employers the flexibility to protect workers from falling to a lower level by using personal fall protection systems (personal fall arrest, travel restraint and work positioning systems) instead of requiring the use of guardrail systems as a primary means, which the prior rule mandated.

Selected Highlights

While there are a number of updates made to the general industry, here are some of the highlights. However, the new rule does not affect the construction or agricultural standards.

Personal Fall Protection System Performance and Use Requirements (ยง1910.140)

The new rule requires worker protection from fall hazards that are at least four feet above a lower level, and establishes requirements for fall protection in specific situations, such as hoist areas, runways, areas above dangerous equipment, wall openings, repair pits, stairways, scaffolds and slaughtering platforms. It also establishes requirements for the performance, inspection, use and maintenance of personal fall protection systems.

Phase-In of Ladder Safety Systems or Personal Fall Arrest Systems on Fixed Ladders (29 CFR 1910.28(b)(9))

Fixed ladder requirements are phased in where employers should have ladder safety or personal fall arrest systems for ladders that extend more than 24 feet, and phases out the use of cages or wells for fall protection following the time line for compliance below.

For portable ladders, rungs and steps should be slip resistant. Portable ladders used on slippery surfaces should be secured and stabilized; not moved, shifted or extended while a worker is on them; and the top steps and caps of stepladders should not be used as steps. Portable ladders should not be fastened together to provide added length unless designed for such use, and they should not be placed on boxes, barrels, or other unstable bases to obtain added height.

Rope Descent Systems (RDS) and Certification of Anchorages (29 CFR 1910.27(b))

Rope Descent Systems (RDS) now have a 300-foot height limit, and building owners are required to affirm, in writing, that permanent building anchorages used for RDS are tested, certified and maintained as capable of supporting 5,000 pounds for each attached worker.

Training (29 CFR 1910.30)

Worker training is a big deal in the new rule. The rule includes a requirement that employers train their workers who use personal fall protection and work in other specified high hazard situations. A qualified person should train these 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.

Time line for Compliance

Most of the rule became effective January 17, 2017, but some provisions have delayed effective dates, including:

May 17, 2017

  • Training exposed workers on fall hazards.
  • Training workers who use equipment covered by the final rule.

November 17, 2017

  • Inspecting and certifying permanent anchorages for rope descent systems.

November 17, 2018

  • 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.
  • Making sure 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.

November 17, 2036

  • Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet.

OSHA has published a Frequently Asked Questions web page to help employers understand the new rule. Knowing the new rule requirements as well as the time line of effective dates can help you keep your walking working surfaces and equipment safer for your workers.

J.A. Rodriguez Jr.
J.A. Rodriguez Jr.

J.A. Rodriguez Jr., CSP, is the CEO of Make My Day Strategies LLC and a global Fortune 100 senior manager. Rodriguez was honored to be selected by EHS Today Magazine as one of "The 50 People Who Most Influenced environmental, health and safety in 2012-2013" and "2014 - 2015."