1. Walking-Working Surfaces and Fall protection Standards
AMI General Meeting
April 19, 2018
Hartefeld National Golf Club
Avondale, PA
Walking-Working Surfaces and Fall protection Standards
A Rule by the Occupational Safety and Health Administration on 11/18/2016
Jim Harrity
Compliance Assistance Specialist,
Philadelphia Area Office

2. Disclaimer
This information is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at

3. Source: U.S. Department of Labor, Bureau of Labor Statistics, Census of Fatal Occupational Injuries

4. Purpose of the New Rule To update the outdated subpart D
To increase consistency with OSHA’s construction standards
To set criteria requirements for personal fall protection equipment
To make the final rule easier to understand and follow.
To give employers greater compliance flexibility.

5. Major Changes Fall Protection Flexibility
Updated Scaffold Requirements
Phase-in of ladder safety systems or personal fall arrest systems on fixed ladders
Phase-out of “qualified climbers” on outdoor advertising structures
Rope descent systems
Adds training requirements
Adds requirements for personal fall protection equipment (final § )
Fixed ladders: Cages and wells
>24’ grandfathered till 2036
New FPAS system / safety cable rope
Replacing must upgrade
Outdoor advertising >24’ / 2 years or FPAS /LSS
No more free climbing in 2 years to 24’

6. Timeline Most of the rule became effective January 17, 2017
Ensuring exposed workers are trained on fall hazards (May 17, 2017),
Ensuring workers who use equipment covered by the final rule are trained (May 17, 2017),
Inspecting and certifying permanent anchorages for rope descent systems (November 20, 2017),
Installing ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures (November 19, 2018),
Ensuring 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 19, 2018), and
Installing ladder safety system or personal fall arrest system on all fixed ladders over 24 feet (November 18, 2036).

7. Organization of Subpart D and Changes to Subpart I
§ – Scope, Application and Definitions § – General Requirements § – Ladders § – Stepbolts and Manhole Steps § – Stairways § – Dockboards
Clear / logical order
/=/ construction standard and ANSI Z359.1
To make things clearer, I have pulled requirements for different items into together, rather than hit it piecemeal 3 times. (introduction, what you have to do and then how).
§ – Duty to Have Fall Protection <= What
§ – Fall Protection Systems Criteria and Practices <= How

8. Organization of Subpart D and Changes to Subpart I
§ – Scaffolds and Rope Descent Systems
§ – Duty to Have Fall Protection
§ – Fall Protection Systems Criteria and Practices
§ –Training Requirements
§ PPE
Clear / logical order
/=/ construction standard and ANSI Z359.1
To make things clearer, I have pulled requirements for different items into together, rather than hit it piecemeal 3 times. (introduction, what you have to do and then how).
§ – Duty to Have Fall Protection <= What
§ – Fall Protection Systems Criteria and Practices <= How

9. §1910.21 Scope and definitions
Consolidates definitions into one section
Adds new definitions to provide clarity
Additional definitions in Subpart I,

10. New Definitions 1910.21 For instance: Combination ladder-
Designated Areas-
Ladder safety system-
Low-Slope Roof-
Personal fall protection system-
Positioning Systems-
Qualified describes a person-
Rope descent system-
Travel restraint system-
Warning Line-
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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11. §
Final §  revises and updates the existing requirements that apply to surfaces in general industry. These provisions address:
Surface conditions and housekeeping (paragraph (a));
Application of loads on walking-working surfaces (paragraph (b));
Access to and egress from walking-working surfaces (paragraph (c)); and
Inspection, maintenance, and repair of walking-working surfaces (paragraph (d)).
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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12. §
Walking-working surfaces are inspected, regularly and as necessary, and maintained in a safe condition;
Hazardous conditions on walking-working surfaces are corrected or repaired before an employee uses the walking- working surface again. If the correction or repair cannot be made immediately, the hazard must be guarded to prevent employees from using the walking-working surface until the hazard is corrected or repaired;
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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13. §
Consolidates and simplifies rules into general requirements, portable ladders, fixed ladders, and mobile ladder stands
Requires inspection before use
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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14. § Ladders
Final § revises and consolidates into one section the existing ladder requirements in (Portable wooden ladders) (Portable metal ladders) (Fixed ladders) (Mobile ladder stands and scaffolds (tower)). Retains many of the existing requirements because OSHA believes they continue to provide an appropriate level of worker safety.
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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15. Angles for Stairs, Ramps, and Ladders Figure D-10
Ladders, Stairs and Ramps
Angles for Stairs, Ramps, and Ladders Figure D-10
Part of Definitions:
Ladder means a device with rungs, steps, or cleats used to gain access to a different elevation.
Stairway (stairs) means risers and treads that connect one level with another, and includes any landings and platforms in between those levels. Stairways include standard, spiral, alternating tread-type, and ship stairs.
Ship stair (ship ladder) means a stairway that is equipped with treads, stair rails, and open risers, and has a slope that is between 50 and 70 degrees from the horizontal.
Alternating tread-type stair means a type of stairway consisting of a series of treads that usually are attached to a center support in an alternating manner such that an employee typically does not have both feet on the same level while using the stairway.
Standard stairs means a fixed or permanently installed stairway. Ship, spiral, and alternating tread-type stairs are not considered standard stairs.
Ramp means an inclined walking-working surface used to access another level.
Spiral stairs means a series of treads attached to a vertical pole in a winding fashion, usually within a cylindrical space.

16. §1910.25 Are installed at a slope of 50 to 70
degrees from the horizontal;
Have open risers with a vertical rise
between tread surfaces of 6.5 to 12 inches
Have minimum tread depth of 4 inches
Have a minimum tread width of 18 inches
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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17. §1910.24 constructed of, or coated with, material that protects
against corrosion
before January 17, 2017 is
capable of supporting its
maximum intended load
after January 17, 2017 is
capable of supporting at least
four times its maximum
intended load
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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18. §1910.24 after January 17, 2017 constructed of, or coated with,
material that protects
against corrosion
Has a corrugated, knurled,
dimpled, or other surface
Is inspected at the start of the
work shift and maintained in
accordance with §
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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19. §1910.25 General requirements for stairways:
Handrails, stair rail systems, and guardrail systems are provided in accordance with §
Vertical clearance above any stair tread to any overhead obstruction is at least 6 feet, 8 inches, as measured from the leading edge of the tread
Stairs have uniform riser heights and tread depths between landings;
Stairway landings and platforms are at least the width of the stair and at least 30” in depth, as measured in the direction of travel;
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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20. §1910.25 20” for platforms before Jan 17, 2017;
22” for platforms after Jan. 17, 2017
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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Stairs installed prior to January 17, 2017.
OSHA will deem those stairs in compliance
if they meet the dimension requirements
specified in Table D-1

21. §1910.26 Updates requirements for dockboards
Adds design and construction requirements to prevent equipment from going over the dockboard edge
Include, but are not limited to, bridge plates, dock plates, and dock levelers
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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22. §
Requires that employers using scaffolds follow the construction standard. 29 CFR part 1926, Subpart L (Scaffolds).
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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23. §
Adds provision allowing use of RDS, which codifies a 1991 OSHA memo allowing RDS
Requires certification of anchorages starting 1 year after final rule published- Nov. 20, 2017
Requires RDS have separate fall arrest system
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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24. §
This section requires employers to provide protection for each employee exposed to fall and falling object hazards. Unless stated otherwise, the employer must ensure that all fall protection and falling object protection required by this section meet the criteria in § , except that personal fall protection systems required by this section meet the criteria of §
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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25. §1910.28 Unprotected sides and edges Fixed Ladders (> 24’)
Outdoor advertising (billboards)
Hoist areas
Holes
Stairways
Dockboards
Scaffold and rope descent systems
Runways and similar walkways
Work on low-slope roofs
Dangerous Equipment
Slaughtering facility platforms
Openings
Repair Pits, Service Pits… (< than 10’)
Walking-working surfaces NOA
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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26. §1910.29 Fall protection systems criteria
Specifies design and installation requirements of each fall protection system available to employers including:
a) General requirements
Guardrail system
Safety nets
Designated areas
Covers
Handrail and Stair rails systems
Cages and wells used with fixed ladders
Outdoor advertising
Ladder safety systems
Personal fall protection systems
Travel Restraint System
Grab handles
<= HOW TO DO IT
a. General
Guardrails: 42” +/- 3”, 200 lb, midrail 21”, 150 lb (19” opening max)
Safety nets: See
Designated areas: 0’ to 6’, 6’ to 15’, 15’ or more b13 (p36) and d (p42)
Covers: 2*, secured
f. Handrail and Stair rails systems: handrail 30” to 38” v/s stair rail 30” => 42”: combined: 36” to 38”: 200 lb.
g. Cages and wells: See dwg
h. Outdoor advertising
i. Ladder safety systems
k. Protection from falling objects, Toeboards: 3.5” high
j. Personal fall protection systems: pfas, work positioning and travel restrain system.
Grab handles: > 12”, 3” clearance, 200 lbs.
Designated Area (temporary and infrequent): p36/37 Work on low-slope roofs,
<6’: guardrail system, safety net system, travel restraint system or Personal fall arrest system.
>6’ to <15”: or designated area.
>15’ or designated area. And work rule.
P42: 200 lb, 34” sag to 39” max, pulling slack, visible at 25’, close to the task, no closer than 6’
Guardrail system means a barrier erected along an unprotected or exposed side, edge, or other area of a walking-working surface to prevent employees from falling to a lower level.
Handrail means a rail used to provide employees with a handhold for support.
Ladder safety system means a system designed to eliminate or reduce the possibility of falling from a ladder. A ladder safety system usually consists of a carrier, safety sleeve, lanyard, connectors, and body harness. Cages and wells are not ladder safety systems.
Carrier means the track of a ladder safety system that consists of a flexible cable or rigid rail attached to the fixed ladder or immediately adjacent to it.
Personal fall protection system means a system (including all components) an employer uses to provide protection from falling or to safely arrest an employee’s fall if one occurs. Examples of personal fall protection systems include personal fall arrest systems, positioning systems, and travel restraint systems.
Travel restraint system means a combination of an anchorage, anchorage connector, lanyard (or other means of connection), and body support that an employer uses to eliminate the possibility of an employee going over the edge of a walking-working surface.

28. 6’ – 15’ = system or designated area (if infrequent and temporary)
Less than 6’ = system
6’ – 15’ = system or designated area (if infrequent and temporary)
More than 15’ = system or designated area and work rule
6 feet
Designated Area
15 feet
FR page 82627, center and top right column: Although OSHA is deleting the proposed access path requirement, the Agency stresses that employers still must train workers, in accordance with final § , about the potential fall hazards in the work area, which includes accessing the work area, and the proper set-up and use of designated areas.
No fall protection, provided work is infrequent and temporary AND a work rule prohibiting employees from going w/in 15’ of edge
NOT TO SCALE

29. Distance From an Edge
When work is performed less than 6 feet (1.6 m) from the roof edge, the employer must ensure each employee is protected from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system.
When work is performed at least 6 feet (1.6 m) but less than 15 feet (4.6 m) from the roof edge, the employer must ensure each employee is protected from falling by using a guardrail system, safety net system, travel restraint system, or personal fall arrest system. The employer may use a designated area when performing work that is both infrequent and temporary.
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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30. Distance From an Edge From the Preamble:
The term ‘‘infrequent,’’ for purposes of the final rule, means that the task or job is performed only on occasion, when needed (e.g., equipment breakdown), on an occasional basis, or at sporadic or irregular intervals. Infrequent tasks include work activities such as annual maintenance or servicing of equipment, monthly or quarterly replacement of batteries or HVAC filters, and responding to equipment outage or breakdown. In these instances, the frequency of exposure to fall hazards is very limited.
By contrast, tasks performed or repeated on a daily, routine or regular basis are not infrequent activities within the meaning of the final rule. Infrequent jobs also do not include those that workers perform as a primary or routine part of their job or repeatedly at various locations during a work shift. A task may be considered infrequent when it is performed once a month, once a year, or when needed.
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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31. §
The employer must train each employee in at least the following topics:
The nature of the fall hazards in the work area and how to recognize them;
The procedures to be followed to minimize those hazards;
The correct procedures for installing, inspecting, operating, maintaining, and disassembling the personal fall protection systems that the employee uses; and
The correct use of personal fall protection systems and equipment, including, but not limited to, proper hook-up, anchoring, and tie-off techniques, and methods of equipment inspection and storage, as specified by the manufacturer.
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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32. §1910.140 Personal fall protection systems.
Scope and application. This section establishes performance, care, and use criteria for all personal fall protection systems. The employer must ensure that each personal fall protection system used to comply with this part must meet the requirements of this section.
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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33. §
§ – Personal Protective Equipment (Personal Fall Protection Systems)
Adds definitions for personal fall protection systems
Adds new section on system and use criteria for:
Personal fall protection equipment (e.g., lanyards, ropes, D-rings, harnesses)
Travel restraint systems
Personal fall arrest systems
Work positioning systems
General: Personal fall protection equipment (e.g., lanyards, ropes, D-rings, harnesses). P62 Travel restraint systems
Personal fall arrest systems p 63
e. Work positioning systems (window cleaner) p64
No more body belts, PFAS
Sections refer to subparts D and I
Dock boards see subpart D
Handrails
261 stairs, subpart D
272 guardrails, subpart D
268/269, Subpart I
§ General requirements.
* * * * *
(g) Paragraphs (d) and (f) of this section apply only to §§ , , ,
, and Paragraphs (d) and (f) of this section do not apply to §§ and
§ [Added and Reserved]
10. Add reserved §
11. Add § to read as follows:
§ Personal fall protection systems.
(a) Scope and application. This section establishes performance, care, and use criteria for all personal fall protection systems. The employer must ensure that each personal fall protection system used to comply with this part must meet the requirements of this section.
(b) Definitions. The following definitions apply to this section:

34. Distance From an Edge
Low-slope roof means a roof that has a slope less than or equal to a ratio of 4 in 12 (vertical to horizontal).
Designated area means a distinct portion of a walking-working surface delineated by a warning line in which employees may perform work without additional fall protection.
Warning line means a barrier erected to warn employees that they are approaching an unprotected side or edge, and which designates an area in which work may take place without the use of other means of fall protection.
Concern:
What is a: Definitions: Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
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35. Main Effective Dates Rule overall: January 17, 2017
Training: 6 months after publication
Building anchorages for RDS: 1 year after publication
Fixed ladder fall protection: 2 years after publication
Installation of ladder safety system on fixed ladders > 24’: 20 years after publication

36. WWW.OSHA.GOV Walking-Working Surfaces and Fall Protection Rule
Final Rule to Update General Industry
Walking-Working Surfaces and Fall Protection Standards
Read the Rule in the Federal Register
Regulatory Text
Fact Sheet
Questions and Answers
Press Release

37. Thank You!