Special Report: Industry facing new standards for safe walking-working surfaces, fall protection
OSHA's industry standards for slip, trip and fall hazards are undergoing changes. After 26 years and a range of iterations, OSHA has published its "Final Rule to Update General Industry Walking-Working Surfaces and Fall Protection Standards," available at www.osha.gov/walking-working-surfaces. The primary purpose of the rule is to better protect workers from falls, which OSHA says are among the leading cause of serious work-related injuries and deaths. OSHA projects that the new standards will prevent 29 deaths yearly and 5,842 lost workdays due to injury.
Specifically, the rule updates general industry standards for slip, trip and fall hazards, which can be found in Subpart D, and adds requirements for personal fall-protection systems, which can be found in Subpart I. The rule, which was published in the Federal Register on Nov. 17, is effective Jan. 17, but allows for phased-in compliance dates for certain provisions. It contains both new and modified standards, as well as new definitions of some terms. One important term is "fall hazard," which is defined as "any condition on a walking-working surface that exposes an employee to a risk of harm from a fall on the same level or to a lower level."
Primary Changes
Major changes include:
Training. Employers must ensure that workers who use personal fall protection and work in other specified, high-hazard situations are trained, and retrained as necessary, on fall hazards and equipment use, in a manner workers can understand. This provision goes into effect May 17.
Ladders. For ladders that extend over 24 feet, personal fall-arrest or safety systems must be installed on new ladders and on replacement ladders/ladder sections. Cages and wells cannot be used as a means of fall protection on new or replacement ladders or sections. Existing ladders must be equipped with a cage, well, personal fall-arrest system, or ladder-safety system. Employers have two years to comply with this provision, which goes into effect on Nov. 17, 2018. Additionally, within 20 years, all cages and wells used as fall protection on existing ladders of 24 feet or higher must be replaced with ladder-safety or personal-fall-arrest systems. As a general standard, OSHA states that ladders must be capable of supporting the maximum load they are expected to bear, and mobile ladder stands and platforms must be capable of supporting four times their maximum intended load. Additionally, before initial use in every shift, each ladder must be inspected for defects that could cause injury.
Fall protection
• Fall protection must be added to unprotected sides or edges that are 4 or more feet above a lower level.
• New requirements are set for fall protection in specific situations, such as hoist areas, runways, wall openings, repair pits, stairways and scaffolds. For example, in the new rule, OSHA identifies "areas above dangerous equipment" as special zones requiring fall protection. The rule defines dangerous equipment as "equipment, such as vats, tanks, electrical equipment, machinery, equipment or machinery with protruding parts, or other similar units, that, because of their function or form, may harm an employee who falls into or onto the equipment." It then specifies that any employee working above such equipment must be protected.
• The requirement to use guardrails as a primary fall-protection method now is being eliminated; therefore, employers may now choose from accepted fall-protection systems they believe will work best (e.g., personal-fall-arrest, travel-restraint and positioning systems).
• Body belts cannot be used as part of a personal fall arrest system.
• Walking and working surfaces must be inspected regularly, and any hazardous conditions corrected and repaired, or guarding put in place. New requirements also have been added for the performance, inspection, use and maintenance of these systems.
• In addition, the rule aligns fall-protection requirements for general industry with those for construction, so operations employing both needn't incorporate two separate sets of standards. Here, understanding definitions is important, said Marie Gargas, senior technical director for environment, health and safety at the Plastics Industry Association, Washington, D.C. For instance, manufacturers should look at whether their employees are performing a construction or maintenance activity, but keep in mind that construction can mean making modifications, not just building a new structure. When in doubt, maintain compliance with the most stringent requirements. "The rule says following the most protective standard will ensure compliance," Gargas said.
The rule also provides some benefit to employers by easing some previous standards. For example, it allows greater flexibility in the selection of fall-protection systems.
Exactly how the new rule will impact the plastics industry, in both benefits and challenges, is yet to be seen, said Gargas. "As companies get into the nuts and bolts of implementation, we hope to hear of any questions or challenges," she said.
An easy first step for plastics manufacturers to take is to review OSHA's Fact Sheet on the rule (www.osha.gov/Publications/OSHA3903.pdf) to ensure that they understand the key points.
For example, the first compliance date to meet involves training. Within six months of the rule's publication, employers must have developed training on fall hazards and on equipment covered by the final rule for applicable employees. So now is the time to look at training programs, determine what's already provided and identify what needs to be added or changed.
For example, while employers have from two to 20 years to implement the new provisions for ladders that extend over 24 feet, they should begin checking facilities for fixed ladders that extend beyond 24 feet, and they should determine if they need to make any changes to bring them into compliance and by when. As another example, Gargas pointed out that portable ladders will need slip- resistant rungs and steps.
With the full rule running 88 pages, there is a lot to digest, even for manufacturers already in compliance with earlier iterations. Gargas is available if employers need help navigating the new rule. "I would certainly be interested in hearing any questions or concerns from the industry," she said.
Lisa Jo Lupo, correspondent
Contact:
Marie Gargas, 202-974-5330, [email protected]
