OSHA’s Final Rule for the General Industry – What are the implications?

Today, the final rule for Walking-Working Surfaces (29 CFR Part 1910, Subpart D) and Personal Protective Equipment (29 CFR part 1910, Subpart I) will be effective, specific to slip, trip and fall hazards (referred to as the final rule in this article).

We will briefly outline what is going to change and what the implications are for workers, employers, safety professionals and everyone who deals with working at height.

Reducing falls (from height)

Obviously, OSHA has a good reason to revise and update its standards. Falls from height and on the same level are the leading causes for work-related injuries and even deaths. A good indication for this is the annual top 10 most cited violations of OSHA standards, where fall protection is leading the list since 2011.

OSHA states that this final rule will significantly reduce the number of worker deaths and injuries, with slip, trip and fall fatalities and injuries in particular. They have made an estimation that with implementing the final rule a total of 29 deaths and 5,842 injuries will be prevented annually in the United States. This alone is enough to implement such a rule.

Besides that, OSHA estimated that a total of 309,5 million USD is saved every year if this rule is fully implemented.

Changes for fall protection

As mentioned earlier, this final rule will affect fall protection standards in general industry, and have an effect on more than one hundred million workers at seven million workplaces : from painters to window cleaners. Clearly, it concerns a lot of people, but what exactly are the main changes?

General requirements
Employers must protect workers from falls from height and have the freedom to select the fall protection solution that works best for their situation. In 1994, similar rules were implemented for construction work. With the final rule, these requirements will become effective in general industry as well. In order to protect their workers, employers can now choose from various fall protection solutions, in contrast to the former rule, where only a guardrail system was permitted:

  • Guardrail systems
  • Safety net systems
  • Personal Fall Arrest systems (the use of a body belt as part of the personal fall arrest system is prohibited)
  • Positioning systems
  • Travel Restraint systems
  • Ladder Safety systems

Furthermore, the final rule requires fall protection systems to comply to performance standards and are inspected and maintained properly before use. Employers or qualified persons must train employees on identifying and minimizing fall hazards, how to use fall protection systems and how to inspect, maintain and store them.

The use of ladders
The final rule also sets requirements for the use of fixed and portable ladders. According to the rule, (fixed) ladders need to be able to support their maximum intended load. Mobile ladders and platforms must even be capable of supporting 4 times their maximum intended load. Each ladder must also be inspected before initial use in order to identify defects that could cause accidents.

An important requirement for fixed ladders over 24 feet is that these need to be featured with fall protection as the use of cages or wells is being prohibited. On fixed ladders, a Vertical Lifeline system can be installed to ensure a user’s safety.

Finally, the rule addresses requirements for the use of portable ladders.

  1. When used on slippery surfaces, they need to be secured and stabilized
  2. The ladder may not be moved, shifted or extended when someone is on it
  3. Top steps and caps shall not be used as steps
  4. Multiple portable ladders may not be fastened together to provide added length, unless designed for this purpose
  5. Ladders may not be placed on boxes, barrels or other unstable bases

You also might consider using a scaffold instead of a ladder. Read more about this topic here.

Changes for facade access solutions

Besides changes for fall protection systems, the final rule has impact on facade access solutions as well. The most important change affects Rope Descent Systems.

Rope Descent Systems (RDS)
Many workers who maintain facades of tall buildings make use of the Bosun’s chair or another form of a rope descent/abseiling system. They hang suspended on heights of 500 feet. Until now, the only standard that addressed requirements for the use of these systems was the ANSI Standard IWCA I14.1, which is not a law. In this final statement, OSHA issues requirements for the use of RDS and makes them federal law.

For workers using a rope descent system (like a Bosun’s chair )and building owners the final rule will have some big consequences:

The final rule states that the use of RDS is permitted. However, the rule adds a height restriction of 300 feet. This means that the use of a Bosun’s chair on a building higher than 300 feet is prohibited by law. So if a building is higher than 300 feet, other facade access solutions need to be used, like a suspended platform or a permanent facade access solution (BMU).

Besides that, building owners need to affirm by writing that permanent building anchors used for RDS have been tested, are certified and maintained in compliance with the requirements of §1910.66, paragraph (g) and (h). The anchors need to be capable of supporting a weight of 5.000 lbs for each worker attached.

Delayed effective days

Some provisions in the final rule have a delayed effective date, as from the 17th of January onward:

  • Ensuring exposed workers are trained on fall hazards and the use of fall protection equipment – 6 months
  • Inspecting and certifying permanent anchorages for rope descent systems – 1 year
  • Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures – 2 years
  • 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 – 2 years
  • Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet – 20 years

Stay up-to-date about rules and regulations

OSHA’s final rule will have serious impact for those working at height, like employers, building owners and safety professionals among others.
To stay informed about this rule and overall changes in standards and requirements for working at height, subscribe below and you will be the first to receive the updates in your inbox!

Source: Occupational Safety and Health Association, Federal Register / Vol. 81, No. 223 (https://www.gpo.gov/fdsys/pkg/FR-2016-11-18/pdf/2016-24557.pdf)

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