Amongst the many hazards of construction, falling on the job remains one of the most dangerous. In fact, OSHA reports that falling is the number one cause of employee injuries and fatalities on worksites each year. In 2016, “there were 370 fatal falls to a lower level out of 991 construction fatalities” meaning that falls represented 37.3% of these fatalities (OSHA 2018).

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These fatalities are preventable, which is why OSHA updated the Walking-Working Surfaces standard in November of 2016. This is the first time this rule has been updated since 1972. After going into effect in January of 2017, new deadlines for compliance have been rolling out to employers and worksite managers. These deadlines aim to gain control of worksite hazards by putting preventative measures in place that reduce or entirely eliminate the number of worker injuries and potentially fatal situations. Overall, this final rule aims to provide:

• More flexibility for employers by increasing the fall protection systems employers may use
• Greater consistency between OSHA’s general industry and construction standards
• Combined knowledge of industry best practices, advances in technology and national consensus standards
• A better understanding of the rule by replacing outdated specification requirements

Since the deadlines for updates to the rule have been rolling out slowly, it is important to stay current on what new requirements are in place and which ones are still pending. Staying ahead of these requirement changes will keep you compliant and keep your workplace safer.

Major Changes in the Final Rule

There is a lot to understand about the new Walking-Working Surfaces and Personal Fall Protection Systems Final Rule, but there are eight major changes to be aware of.

1. Fall Protection Flexibility: This allows employers to choose from a range of accepted fall protection systems based on the needs of their worksite and workers. “It eliminates the existing mandate to use guardrails as the primary fall protection method and gives employers the flexibility to determine what method they believe will work best in their particular workplace situation” (OSHA 2016).
2. Updated Scaffold Requirements: The outdated general industry scaffold standards have been replaced, and employers must comply with the most recent construction scaffold standards from OSHA.
3. Phase-In of Ladder Safety Systems to Personal Fall Arrest Systems on Fixed Ladders: Over the next 20 years, fixed ladders that extend over 24 feet must be equipped with “personal fall arrest systems” (OSHA 2016). Existing systems with cages and wells can be grandfathered into this new standard, but all new ladders and any replacement ladders or ladder sections must be equipped with personal fall arrest systems.  
4. Phase-Out of the “Qualified Climber” Exception in Outdoor Advertising: Previously, some workers could be designated as “qualified climbers” when working in outdoor advertising, allowing them to climb fixed ladders on billboards without any form of fall protection. This exception is being phased out in the same timeline as the phase-in for new safety requirements for fixed ladders.
5. Rope Descent Systems (RDS) and Certification of Anchorages: This “prohibits employers from using RDS at heights greater than 300 feet above grade unless they demonstrate it is not feasible or creates a greater hazard to use any other system above that height.” Additionally, these permanent anchorages must be regularly inspected, certified and maintained as being capable of supporting at least 5,000 pounds per employee attached. (OSHA 2016)
6. Personal Fall Protection System and Performance and Use Requirements: Body belts may no longer be used as a part of a personal fall arrest system, and all systems have new requirements for their performance, inspection, use and maintenance.
7. Inspection of Walking-Working Surfaces: Employers must “inspect walking-working surfaces regularly and as needed and correct, repair, or guard against hazardous conditions” (OSHA 2016).
8. Training: Information, training and retraining must be provided to all workers who use or may use personal fall protection.

Another change to take note of is providing appropriate precautions around unprotected edges. This rule “requires employers to protect workers from fall hazards along unprotected sides or edges that are at least 4 feet above a lower level” (OSHA 2016)  with specific guidelines for the use of any of the following:

• Guardrail Systems
• Safety New Systems
• Personal Fall Arrest Systems
• Positioning Systems
• Travel Restraint Systems
• Ladder Safety Systems

Current and Upcoming Updates

Since going into effect in January 2017, the deadlines for several updates have already passed, and there are more upcoming. Here is the current timeline of new and pending rule changes in the Subpart D requirements:

"May 17, 2017: Deadline by which employers must train employees on fall and equipment hazards.

November 20, 2017: Testing & certification of anchorages.

November 19, 2018: Deadline by which employers must equip existing fixed ladders with one of the following solutions: cage, well, ladder safety system, or personal fall arrest system.

November 19, 2018: After this date, employers must begin equipping new & renovated fixed ladders with a ladder safety system or personal fall arrest system.

November 18, 2036: Deadline by which all fixed ladders must be equipped with a ladder safety system or personal fall arrest system in place of cages and wells." (Rooftop Anchor, 2017)

The next upcoming requirement to be aware of is the November 19, 2018 deadline for equipping existing fixed ladders (over 24 feet) with the proper fall protection or personal fall arrest systems that don’t already have fall protection. Prioritizing compliance and updating your current systems when appropriate will keep operations running smoothly.

Flexibility in Fall Prevention Safety and Compliance

Any time there are updates to existing standards, it can feel like a burden on employers to implement those changes. Fortunately for employers and workers alike, the new OSHA Walking-Working Surfaces and fall protection standard has been designed to give employers more flexibility on which fall protection systems to us on their worksites. This makes staying compliant both less complicated and less costly.

If you are updating your own worksite to stay in compliance with these new standards and feel unsure of where to begin, we’re here to help. Whether by providing training or making product recommendations, our safety experts are here to help you decipher these new regulations and to work with you to develop a prevention program that will safeguard your worksite. Contact us today!

References:

OSHA (2016) Walking-Working Surfaces and Personal Fall Protection Systems Final Rule Frequently Asked Questions. Retrieved from: https://www.osha.gov/walking-working-surfaces/faq.html

OSHA (2016) OSHA’s Final Rule to Update, Align, and Provide Greater Flexibility in its General Industry WalkingWorking Surfaces and Fall Protection Standards. Retrieved from: https://www.osha.gov/Publications/OSHA3903.pdf

Rooftop Anchor (2016) 7 Reasons the New OSHA Walking Working Surfaces Rule Will Affect You. Retrieved from: http://www.rooftopanchor.com/new-osha-walking-working-surfaces-rule/