OSHA Issues Final Rule to Update the General Industry Walking-Working Surfaces and Fall Protection Standards

On November 17, 2016 the Occupational Safety and Health Administration (OSHA) issued its final rule which updates the General Industry Walking-Working Surfaces standards. The updated rule applies to all workplaces and covers work areas including platforms, elevated walkways, floors, ladders, stairs, scaffolding, and roofs. The rule also is specific to fall hazards and includes new sections under the Personal Protective Equipment regarding the use of personal fall protection systems.
The final rule, which goes into effect January 17, 2017, aligns many requirements under General Industry with Construction standards and is meant to recognize advances in technology and options available to prevent or reduce employee injuries from falls. Alignment of the two standards came about when OSHA realized that many companies can perform activities that touch on both General Industry and Construction within one operation, and determined that having consistent standards would allow for easier compliance management. Minor updates included some changes to definitions under Walking and Working standards, while the significant updates address fall protection, prohibition of body belts as part of fall arrest systems, rope descent systems, and employee training on fall protection systems and equipment. Some examples of fall protection allowances include the elimination of the mandatory use of guardrails as a primary fall protection method. Employers can now choose accepted fall protection systems that work for their work tasks and situation. Also, the General Industry scaffold standards have been removed and replaced with the requirement that employers comply with OSHA’s construction scaffold standards. Under the final rule, employers may choose from the following fall protection options:
  • Guardrail System – A barrier erected along an unprotected or exposed side, edge, or other area of a walking-working surface.
  • Safety Net System – A horizontal or semi-horizontal, cantilever-style barrier that uses a netting system to stop a fall.
  • Personal Fall Arrest System – A system that arrests/stops a fall before contacting a lower level. The final rule prohibits the use of body belts as part of a personal fall arrest system.
  • Positioning System – A system of equipment and connectors that, when used with a body harness or body belt, allows a worker to be supported on an elevated vertical surface, (e.g., wall, window, etc) and work hands free.
  • Travel Restraint System – A system to eliminate the possibility of a worker going over an unprotected edge or side of a walking-working surface.
  • Ladder Safety System – A system attached to a fixed ladder designed to eliminate or reduce the possibility of a worker falling off the ladder. Cages and wells are not considered ladder safety systems.
The rule also adds a requirement that employers must now ensure that the employees who use personal fall protection or that work in other specified high hazard situations are properly trained, and retrained as necessary. OSHA requires that a qualified person must train the employees on identifying and minimizing fall hazards; use personal fall protection systems and/or rope descent systems; and maintenance, inspection, and storage of equipment or systems used for fall protection. The majority of the final rule goes into effect on January 17, 2017 but some provisions have delayed enforcement dates as follows:
  • Training employees on fall equipment and hazards (May 17, 2017)
  • Inspecting and certifying anchorages (November 20, 2017)
  • Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections (November 19, 2018)
  • Equip existing fixed ladders over 24 feet with a cage, well, personal fall arrest system, or ladder safety system (November 19, 2018)
  • Replacing existing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet (November 18, 2036)
Regardless of the enforcement delays on some provisions, it is recommended that companies review their operations and prepare themselves for compliance ahead of the enforcement dates to allow for any adjustments or revisions to their compliance programs to meet the requirements on time. It’s also important to keep in mind that along with the new final rule there are still Local Emphasis Programs (LEP’s) taking place by OSHA regions that are conducting inspections for fall hazards and other associated subjects. SGIA will continue to monitor the implementation of this updated rule. Sign up to receive the most up-to-date regulatory and legislative information about specialty imaging.
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