Audit, Compliance and Risk Blog

The Occupational Safety and Health Administration (OSHA) has issued massive revisions to its regulations requiring most employers (“General Industry”, in OSHA parlance), to protect employees from slip and fall hazards in most workplace contexts, including:

• Walking-working surfaces – to reduce slips and falls even when floors are level or nearly level.

• Stairs and ladders – used by employees to travel between levels within a workplace, or to work at elevation from the floor.

• Barriers at the perimeters of elevated work areas -- passive protection such as guardrails and toeboards against employee falls or being hit by falling objects.

• Personal fall protection systems – used by employees working at significant elevations, including window washers and billboard crews (note OSHA issued a new standard (29 CFR 1910.140) covering these systems effective January 17, 2017).

Specifically, the rules update general industry standards addressing slip, trip, and fall hazards (subpart D of 29 CFR part 1910), and add requirements for personal fall protection systems (subpart I). These revisions consolidate and complete rulemaking efforts underway sporadically since as long ago as 1990. They incorporate advances in technology, industry best practices, and national consensus standards during this time. They also incorporate recommendations from earlier rounds of rulemaking, and respond to several hundred formal comments on OSHA's last proposal (in 2014).

The revised rules are effective January 17, 2017 (see 81 Fed. Reg. 82494 (November 18, 2016)), although some deadlines for initial compliance are later, and many pre-existing situations can continue without upgrades.

This note discusses the revised requirements for walking-working services, and for pathways (such as stairs and ladders) between levels. The next note will discuss fall protection systems and training requirements.

Requirements For Walking-Working Surfaces

For purposes of these standards, OSHA defines a “walking-working surface” very generally, as “any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.” OSHA’s general rule (29 CFR 1910.22) updates and clarifies existing requirements, covering the following:

• Housekeeping 

  • Keep all places of employment, passageways, storerooms, and service rooms, and walking-working surfaces in a “clean, and orderly, and in a sanitary condition”.

  • Keep workroom floors clean and—to the extent possible—dry.

  • Keep all walking-working surfaces free of hazards such as sharp and protruding objects, loose boards, corrosion, leaks, spills, snow, and ice.

• Floor loadings 

  • Ensure that each walking-working surface can support the maximum intended load for that surface (this applies to the many employers who do not own their buildings, who may need to obtain information from the building owner).

• Access and Egress

  • Provide, and ensure each employee uses, a safe means to access and egress from walking-working surfaces (this rule does not provide guidance; consider OSHA’s Exit Routes (Means of Egress) Standard).

• Inspection, Maintenance and Repair

  • Inspect walking-working surfaces, regularly and as necessary.

  • Maintain each walking-working surface in a safe condition.

  • Correct or repair hazardous conditions on walking-working surfaces before an employee uses the surface again; guard hazardous surfaces to keep employees out until the hazard is corrected or repaired.

  • Ensure that a qualified person performs or supervises any correction or repair involving the structural integrity of a walking-working surface.

Requirements For Stairways

Effective January 17, 2017, OSHA defines stairway (stairs) to mean “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.” OSHA defines standard stairs to mean “a fixed or permanently installed stairway. [However,] Ship, spiral, and alternating tread-type stairs are not considered standard stairs.” (This definition replaces OSHA’s former definition, for “fixed industrial stairs”, in order to be more general).

OSHA does not allow employers to install spiral, ship, or alternating tread type stairs, unless standard stairs are not feasible, and requires these non-standard stairs to be installed, used and maintained in accord with manufacturer’s instructions.

• When to install

• OSHA generally requires employers to install fixed stairs under the following circumstances: 

  • To provide access from one level to another where your operations require regular and routine travel between levels.

  • For access to operating platforms on equipment that requires regular and routine attention during operations.

• Construction and installation requirements

OSHA specifies several design criteria for standard stairways, and for individual standard stairs within such stairways. These include specifications for:

• Handrails, stair rail systems, and guardrail systems.

• Railings and handrails.

• Vertical clearance.

• Uniform angle of rise, riser height, and tread width; all within specified acceptable ranges.

• Landings and platforms.

• Doors and gates opening onto stairway.

• Stair strength.

Requirements for Ladders

• General design and construction requirements 

  • Rungs, steps, and cleats must be parallel, level, and uniformly spaced 10 to 14 inches apart, except that:

  • Rungs and steps in elevator shafts must be spaced 6 to 16.5 inches apart.

  • Fixed ladder rungs and steps on telecommunication towers must be spaced no more than 18 inches apart.

  • Steps on stepstools must be spaced 8 to 12 inches apart.

  • Rungs, steps, and cleats have a minimum clear width of 11.5 inches on portable ladders and 16 inches on fixed ladders (exceptions apply, including: narrow rungs not designed to be stepped on, such as those on the tapered end of orchard ladders; rungs and steps of manhole entry and rolling ladders used in telecommunication centers must have a clear width at least 8 inches; and stepstools).

  • Wooden ladders must not be coated with any material that may obscure structural defect.

  • Metal ladders must be made with corrosion-resistant material or be protected against corrosion.

  • Ladder surfaces must be free of puncture and laceration hazards.

• Use requirements:

  • Ladders must be used only for the purposes for which they were designed.

  • Ladders must be inspected before initial use in each work shift, and more frequently as necessary, to identify any visible defects that could cause employee injury.

  • A ladder with structural or other defects must be tagged immediately “Dangerous: Do Not Use” or similar language and removed from service until repaired in accordance with OSHA requirements or replaced.

  • Each employee must face the ladder when climbing up or down it.

  • Each employee must use at least one hand to grasp the ladder when climbing up and down.

  • No employee may carry any object or load that could cause the employee to lose balance and fall while climbing up or down the ladder.

• Additional category-specific standards apply to fixed ladders, portable ladders, mobile ladder stands and platforms, and step bolts and manhole steps.

These requirements do not apply to ladders used for emergency operations (such as fire and police), or to ladders designed as integral parts of machinery or equipment.

Requirements for Dockboards

OSHA defines a dockboard to mean “a portable or fixed device that spans a gap or compensates for a difference in elevation between a loading platform and a transport vehicle. Dockboards include, but are not limited to, bridge plates, dock plates, and dock levelers.”

Employers using dockboards to bridge the gaps between vessels or other carriers and loading docks must meet the following requirements, effective January 17, 2017:

• Dockboards must be capable of supporting the maximum intended load.

• Dockboards put into initial service on or after January 17, 2017 must be designed, constructed, and maintained to prevent transfer vehicles from running off the dockboard edge.

• Portable dockboards must be secured, by anchoring them in place or using equipment or devices to prevent them from moving out of a safe position.

• Measures such as wheel chocks or sand shoes must be used to prevent the transport vehicle on which a dockboard is placed, from moving while employees are on the dockboard.

• Portable dockboards must be equipped with handholds or other means to permit them to be handled safely.

These requirements replace reliance on a reference to a U.S. Department of Commerce standard with details within OSHA’s own standard.

Implementation Checklist

Does the organization operate any workplaces where workers may be exposed to:

• Fall hazards.

•  Hazards from falling objects.

If so, does the organization assess those hazards:

• Walking-working surfaces.

•  Movement between levels (e.g., stairs or ladders).

•  Elevated working areas from which workers could fall or drop objects onto co-workers below

Does the organization provide protective measures?

Is the organization reconsidering hazards and protective measures in order to provide compliance with newly-revised OSHA requirements?

Where Do I Go For More Information?

Information available via the Internet includes:

• OSHA webpage for this rulemaking 

• OSHA revisions (as published in the Federal Register; 513 pages including discussion) 

Specialty Technical Publishers (STP) provides a variety of single-law and multi-law services, intended to facilitate clients’ understanding of and compliance with requirements. These include:

• OSHA Auditing - Federal Compliance Guide: Facilities: The Complete Safety & Health Audit Checklist 

• OSHA Compliance: A Simplified National Guide

• OSHA State Differences Summaries and Checklists

• OSHA Auditing - California Occupational Health and Safety Audit Guide

• Federal Toxics Program Commentary

• Workplace Violence Prevention: A Practical Guide to Security on the Job

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