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OSHA’s Updated Walking Working Surfaces and Fall Protection Standards are Now in Effect OSHA’s Updated Walking Working Surfaces and Fall Protection Standards are Now in Effect

OSHA’s Updated Walking Working Surfaces and Fall Protection Standards are Now in Effect

On January 17, 2017, the U.S. Occupational Safety and Health Administration’s (“OSHA”) final rule revising and updating its general industry walking-working surfaces standards and personal fall protection systems went into effect. While the new rule does not impact construction standards, it does affect employees in all general industry workplaces, such as warehousing, utilities, retail, window cleaning, and outdoor advertising, among others.

Regarding walking-working surface conditions, the rule adds several provisions to 29 C.F.R. § 1910.22, Subpart D. For example, employers must now ensure that work surfaces are free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow, and ice. Employers must also provide a safe route of ingress and egress to and from walking-working surfaces, and ensure each employee uses the secure route. Employers are also now required to ensure that walking-working surfaces are inspected regularly and maintained in a safe condition.

The rule also adds specific general industry requirements for fall protection. For example, employers must now protect employees from fall hazards on walking-working surfaces with an unprotected edge that is four feet or more above a lower level. The rule also establishes requirements for fall protection in specific situations such as hoist areas, wall openings, repair pits, stairways, and areas above dangerous equipment.

Also related to fall protection, and as a potential benefit to employers, the rule eliminates the mandate requiring employers to use guardrails as the primary fall protection method, and gives employers more flexibility to select a fall protection system that fits the employer’s specific needs. Employers are now permitted to choose from fall protection systems such as a guardrail system, safety net system, personal fall arrest system, travel restraint system, positioning system, or ladder safety system.

The rule also establishes training requirements related to fall and equipment hazards. Employers must now ensure employees who are exposed to fall hazards are trained, and retrained when necessary, on the following topics: how to recognize and minimize fall hazards; the correct procedures for installing, inspecting, operating, maintaining, and disassembling personal fall protection systems; and the correct use of personal fall protection systems and equipment.

Although the final rule became effective on January 17, 2017,[1] employers should take note that OSHA provided delayed compliance dates for several requirements including:
  • Training employees on fall and equipment hazards – 6 months;
  • Inspection and certification of permanent building anchorages – 1 year;
  • Installation of fall protection (personal fall arrest systems, ladder safety systems, cages, wells) on existing fixed ladders (over 24 feet) that do not have any fall protection – 2 years;
  • Installation of ladder safety or personal fall arrest systems on new fixed ladders (over 24 feet) and replacement ladders/ladder sections – 2 years; and
  • Installation of ladder safety systems or personal fall arrest systems on all fixed ladders (over 24 feet) – 20 years.
With the final rule now in effect, employers are encouraged to fully examine their walking-working surface and fall protection policies, practices, and procedures to ensure they are in compliance with the updated and revised standards. For more information on the new standards, or for assistance in implementing changes to your current policies, contact Charles E. Bush at or any other member of our Labor, Employment and Immigration group.

This publication is intended for general information purposes only and does not and is not intended to constitute legal advice. The reader should consult with legal counsel to determine how laws or decisions discussed herein apply to the reader’s specific circumstances. 
[1] Please note that specific states may have different effective dates (i.e., in Indiana, the rules will not go into effect until 60 days after the federal effective dates). 
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