Skip to main content
Skip global navigation and go to main content

First citation issued under Walking-Working Surfaces shows OSHA means business

Employer may pay well over $1 million for violations of Subpart D

Posted August 9, 2017

Just days after the requirements under new Subpart D, “Walking-Working Surfaces (WWS),” became effective, OSHA initiated an inspection of an aluminum manufacturer and found multiple violations under the standard.

Among the 51 safety and health violations and proposed penalties of $1,922,895, OSHA found that fixed ladders, portable ladders, skylights, stairs, loading docks, and other walking-working surfaces were not compliant. One violation for failure to ensure that the side rails of a ladder extended 42 inches above the top of the access level or landing platform served by the ladder resulted in a proposed penalty of $9,959.00.

This citation is not an isolated incident. Since the January 17, 2017 effective date of the new rule, OSHA has inspected and cited at least a dozen employers for multiple WWS violations. Included in the various citations were failures to:

  • Conduct required inspections (1910.22(d)(1)) - $5,070
  • Guard unprotected sides and edges 4 feet or more above a lower level (1910.28(b)(1)) - $36,215
  • Prevent employees from falling into holes (1910.28(b)(3)(i)) - $12,675
  • Ensure strength criteria for guardrail systems (1910.29(f)(7)) - $9,054
  • Guard runways and walkways 4 feet or more above a lower level (1910.28(b)(5)(i)) - $11,408
  • Correct or repair walking-working surface hazardous conditions (1910.22(d)(2)) - $6,300
  • Keep all walking-working surfaces in clean, orderly, and sanitary condition (1910.22(a)(1)) - $19,555
  • Ensure that each walking-working surface can support the maximum intended load for that surface (1910.22(b)) - $114,000

It’s been six months since OSHA issued the new requirements to prevent slips, trips, and falls in general industry workplaces. At this point, employers must have conducted a hazard assessment, implemented required fall protection, developed an inspection schedule, trained employees, etc. If not, employers can reasonably expect to be cited for not complying with Subpart D requirements.

Slips, Trips and FallsJ. J. Keller offers a wide range of products and services to help you comply with slips, trips and falls regulations.


J. J. Keller's FREE Workplace SafetyClicks™ email newsletter brings quick-read workplace safety and compliance news right to your email box.

Sign up to receive Workplace SafetyClicks™.