The Updated Walking Working Surfaces OSHA Standard – 27 Years in the Making
Duty to Have Fall Protection
Recently, significant changes were made to OSHA’s General Industry Walking Working Surfaces standard. Because a large portion of working Americans are affected, it is important workers and employers understand these changes and adapt the workplace to ensure compliance.
The history and rationale for the changes began in April 1990 when the U.S. Department of Labor, Occupational Safety and Health Administration (OSHA) proposed to amend General Industry 29 CFR Part 1910 – Subpart I – Personal Protective Equipment by adding criteria for equipment pertaining to fall protection systems to include fall arrest systems, work positioning systems, travel restricting systems, and fall protection systems for climbing. OSHA also proposed to amend Subpart D – Walking and Working Surfaces in order to focus on trip/slip/fall hazards, a leading cause of serious and fatal injuries. The changes are also an attempt to eliminate ambiguities and redundancies, address areas not covered in the existing standards, and consolidate and simplify many of the provisions contained in the existing standard. As a result, 1910 Subpart D Walking Working Surfaces was completely revised and renumbered to reflect these changes.
This particular blog article is targeted at understanding 1910.28 Duty to have fall protection and falling object protection.
At the epicenter of the Duty to Have Fall Protection and Falling Object Protection 1910.28 is the overall requirement that the employer must ensure that each employee, on a walking-working surface with an unprotected side or edge of four (4) feet or more above a lower level, is protected from falling. This differs from 1926 Construction Fall Protection trigger heights starting at six (6) feet. Within the General Industry Standard, there are several acceptable methods for protecting workers from falling. These include guardrail systems, safety net systems, and personal fall arrest systems (i.e., personal fall arrest, travel restraint, or positioning systems). If an employer can demonstrate that these methods are not feasible or create a greater hazard, a fall protection plan can be developed. As in the 1926 Construction version of the Fall Protection Standard, the burden of proof is on the employer to establish that a method is not feasible or creates a greater hazard and why it is necessary to implement a fall protection plan in a particular work operation.
The standard also identifies specific fall protection methods based on the hazard. Included are specifications for:
- hoist areas,
- runways and similar walkways,
- dangerous equipment,
- pits (repair pits, service pits, and assembly pits less than ten (10) feet in depth),
- fixed ladders,
- outdoor advertising (billboards),
- rope descent systems,
- work on low-slope roofs,
- slaughtering facility platforms, and
- walking-working surfaces not otherwise addressed.
Protection from falling objects by use of hard hats, toeboards, and other methods is also addressed in a separate section within 1910.28.
For additional blog articles on the new Subpart D Walking Working Surfaces, check out the linked posts below.