The newly revised standard on walking and working surfaces was published on November 18, 2016 and went into effect on January 17, 2017. We previously covered parts of the standard and will continue below with a summary of the remainder of the standard.
Previously at 1910.30(a), under the revised rules, OSHA broke out dockboards to make it a stand-alone standard. While it is a short standard, there is nothing remarkable beyond what one would normally expect regarding design and use of dockboards. Much emphasis is placed on assuring dockboards are capable of supporting the maximum load that could reasonably be expected to be put them. Also, OSHA stressed the need to take precautions against vehicle (truck, semi-trailer, trailer or rail car) movement while employees are on them. Finally, there is, as with any other equipment, an unwritten expectation that dockboards be inspected.
1910.27 Scaffolds and rope descent systems
At 1910.27(a), OSHA requires general industry employers to use the construction industry scaffolding standard found at 29 CFR part 1926, Subpart L which has long been recognized as a more effective standard than the one found in the general industry standards.
The remainder of this standard deals with rope descent systems defined as a suspension system that allows an employee to descend in a controlled manner and, as needed, stop at any point during the descent.
1910.28 Duty to have fall protection and falling object protection
This standard is somewhat similar to the old fall protection standard found at 29 CFR part 1910.23 in which we found the four-foot rule. That rule has not changed. Employers still must provide fall protection for workers working at four feet or more above an adjacent surface or less than four feet if the worker could fall into an area which presents a hazard such as onto dangerous equipment.
The standard provides details on the requirements for those workers at hoistways where the fall hazard exceeds four feet. If a safeguard such as a guardrail system, gate, or chains is removed, and an employee must lean through or over the edge, the employee must use a personal fall arrest system. Remember that old maxim, PPE is always a last resort. It will be far better to install a gate providing 100% passive fall protection than a chain, removable section or gate which still allows a worker to fall than it is to require the use of personal fall protection equipment.
Employers must also take steps to prevent workers from falling into holes such as skylights, ladder openings and stairway openings.
There are a couple of exceptions to the four-foot rule. One of those is repair pit, service pit, or assembly pit that is less than 10 feet deep. However, additional precautions must be taken to assure workers do not fall into such pits.
Fixed ladders now will require fall protection when the ladder length is 24 feet or more or if the fall distance from an elevated ladder which is less than 24 feet long exceeds 24 feet. One point of note is, OSHA is phasing out cages. Any fixed ladder installed after November 19, 2018, must be equipped with a personal fall arrest system or a ladder safety system as cages are no longer accepted as fall protection after this date. Further, all such fixed ladders must have a personal fall arrest system or safety system by November 18, 2036. In truth, cages offer very little in the way of fall protection. OSHA stated, if you allow me to jump ahead momentarily, that cages and wells are to be designed, constructed, and maintained to contain employees in the event of a fall, and to direct them to a lower landing. In other words, cages should be designed to direct the climber to fall at the base of the ladder should he/she fall.
In addition to site or industry-specific work areas such as outdoor advertising, low-sloped roofs and slaughtering facility platforms, the new standard also addresses protection from falling objects. This is something we have seen in the past in scaffolding standards.
1910.29 Fall protection systems and falling object protection-criteria and practices
This standard covers details of design and installation of various fall protection systems such as guard rails, stair and hand rails, safety net systems, designated areas, personal fall protection systems and others. It also provides specific details on the construction of systems intended to protect workers from falling objects.
One change you may notice is regarding the height of stair and hand rails. Under the old standard, a stair rail and hand rail were required to be between 30 and 34 inches high. This height has been raised to provide consistency with NFPA 101-2012 and to accommodate a taller population of workers. Otherwise, there is little change from what we are already accustomed to.
1910.30 Training requirements
Any employee who uses personal fall protection systems or who is required to be trained by any of the other standards must be trained. Training must cover:
The nature of the fall hazards in the work area and how to recognize them;
The procedures to be followed to minimize those hazards;
And be commensurate with the hazards and equipment needed to prevent fall protection whether using personal fall protection, dockboards, designated areas, etc.
Training must occur before May 17, 2017.
As with most other OSHA standards, workers will require retraining when there are changes that affect fall protection equipment or understanding or when there is reason to believe workers do not have the understanding to use fall protection methods properly.
Training must be presented in a way that workers understand it.
The new standard on personal protective equipment, establishes performance, care, and use criteria for all personal fall protection systems. It also specifies details for the design and manufacture of fall protection system-related equipment such as ropes, carabiners, snap hooks, etc.
Among the most challenging points of this standard, and one of the most overlooked, particularly in general industry, is rescue. This is not a new requirement but has not, until now, been found in the general industry standards. Employers must provide for prompt rescue of each employee who falls. If there is a worker using a personal fall protection system, such as fall arrest, there must be a plan as to how the worker will be rescued in a way that will minimize suspension time.
Appendix C provides additional information on several related topics including planning, rescue and calculating fall distances. Employers may find this information to be a useful addition to the standards.
Appendix D to Subpart I of Part 1910 – Test Methods and Procedures for Personal Fall Protection Systems Non-Mandatory Guidelines
Appendix D provides detailed information on test methods for personal fall protection systems to determine if they meet the system performance criteria specified in paragraphs (d) and (e) of 1910.140.