OSHA Updates Fall Protection and Walking-Working Surface Standards

 The final rule applies to all general industry workplaces and covers all walking-working surfaces, which include horizontal and vertical surfaces such as floors, stairs, roofs, ladders, ramps, scaffolds, elevated walkways, and fall protection systems. The rule also includes a new section under the general industry Personal Protective Equipment standards that establishes employer requirements for using personal fall protection systems.

Major Changes
Fall protection flexibility (§1910.28(b)). The final rule allows employers to protect workers from falls by choosing from a range of accepted fall protection systems, including personal fall protection systems. 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.

• The final rule allows employers to use non-conventional fall protection practices in certain situations, such as designated areas on low-slope roofs for work that is temporary and infrequent and fall protection plans on residential roofs when employers demonstrate guardrail, safety net, or personal fall protection systems are not feasible or create a greater hazard (§1910.28(b)(1) and (b)(13));  
• Updated scaffold requirements (§1910.27(a)). The final rule replaces the outdated general industry scaffold standards with the requirement that employers comply with OSHA's construction scaffold standards; 
• Phase-in of ladder safety systems or personal fall arrest systems on fixed ladders (§1910.28(b)(9)). The final rule phases in over 20 years a requirement to equip fixed ladders (that extend over 24 feet) with ladder safety or personal fall arrest systems and prohibits the use of cages and wells as a means of fall protection after the phase-in deadline. The final rule grandfathers in cages and wells on existing ladders, but requires during the phase-in period that employers equip new ladders and replacement ladders/ladder sections with ladder safety or personal fall arrest systems; 
• Rope descent systems (RDS) and certification of anchorages (§1910.27(b)). The final rule codifies OSHA's memorandum for employers who use RDS to perform elevated work. The final rule 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. In addition, the final rule requires building owners to provide and employers to obtain information that permanent anchorages used with RDS have been inspected, tested, certified, and maintained as capable of supporting at least 5,000 pounds per employee attached.
• Personal fall protection system performance and use requirements (§1910.140). The final rule, which allows employers to use personal fall protection systems (i.e., personal fall arrest, travel restraint, and positioning systems), adds requirements on the performance, inspection, use, and maintenance of these systems. Like OSHA's construction standards, the final rule prohibits the use of body belts as part of a personal fall arrest system;
• Inspection of walking-working surfaces (§1910.22(d)). The final rule requires that employers inspect walking-working surfaces regularly and as needed and correct, repair, or guard against hazardous conditions; and
• Training (§1910.30). The final rule adds requirements that employers ensure workers who use personal fall protection and work in other specified high hazard situations are trained, and retrained as necessary, about fall and equipment hazards, including fall protection systems. Employers must provide information and training to each worker in a manner the worker understands.

Timeline
Most of the rule becomes effective 60 days after its publication in the Federal Register (January 17), but some provisions have delayed effective dates, including:

• Ensuring exposed workers are trained on fall hazards (6 months);
• Ensuring workers who use equipment covered by the final rule are trained (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); and
• 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).

More details on the Walking-WorkingSurfaces and Personal Fall Protection Systems Final Rule FAQs can be found on the OSHA website.

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