OSHA Walking-Working Surfaces Frequently Asked Questions

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OSHA Walking-Working Surfaces Answers

What is the OSHA walking-working surfaces rule?

According to the Occupational Safety and Health Administration (OSHA), general industry workers are exposed to walking and work surface hazards that can result in slips, trips, falls, and other injuries or fatalities.

The new requirements under Subpart D, "Walking-Working Surfaces," provide employers with the flexibility to decide which fall protection method or system works best for the work operation. OSHA says that these multiple options, along with required inspections and training, will help employers prevent and eliminate walking-working surface hazards.

What is encompassed in the rule?

OSHA's revisions to Subpart D, "Walking-Working Surfaces," include a reorganization of the existing rule to make it clearer, necessitating a reformat of the entire subpart (29 CFR 1910.21 - .30). However, the most significant changes cover NEW requirements for a variety of walking-working surfaces throughout Subpart D, as well as introducing additional new requirements under other general industry standards, including Subpart I, "Personal Protective Equipment."

To learn what the entire ruling encompasses in detail, download the free Walking-Working Surfaces: OSHA Takes Major Steps to Overhaul Slips, Trips, and Falls Standard whitepaper.

Who needs to comply?

All general industry workplaces. This is approximately 6.7 million establishments employing more than 100 million workers, including:

  • Manufacturing
  • Warehousing
  • Utilities
  • Oil & gas extraction
  • Retailers
  • Offices

Why is compliance critical?

According to Bureau of Labor Statistics data, slips, trips, and falls are the leading cause of workplace fatalities and injuries in general industry. OSHA says the new requirements will prevent nearly 30 workplace fatalities and 6,000 lost-workday injuries annually. This equates to an estimated cost savings of more than $300 million each year for employers affected by the new requirements.

What are the requirements for the employer?

In summary, the Agency kept many of the requirements under the old standard.

However, OSHA also introduced key NEW provisions which require employers now to:

  • Identify and evaluate slip hazards, trip hazards, and fall hazards in the workplace. This assessment must be done in accordance with 1910.132(d)(2) which requires the employer verify that this was performed through a written certification which identifies:
    • The workplace evaluated;
    • The person certifying that the evaluation was performed; and
    • The date(s) of the hazard assessment.
  • Provide appropriate personal protective equipment or fall protection systems (i.e., personal fall arrest system, travel restraint system, or a positioning device) to address the slip, trip, and fall hazards identified during the above required hazard assessment. 
  • Conduct regular inspections and maintenance of all walking-working surfaces in the workplace.
  • Provide training that enables employees to recognize the hazards of falling and the procedures to be followed to minimize these hazards, including the use of personal fall protection, proper ladder climbing techniques, etc.

Are there program requirements to satisfy the regulations?

OSHA does NOT specify "program" requirements. Best practice, however, would include a safety and health management system that includes written plans which address the new requirements under Subpart D, including (but not limited to):

  • Fall Protection (General),
  • Inspections (including, but not limited to, those for walking and work surfaces – an opportunity to help an employer address other required inspection in their workplace),
  • Equipment (e.g., Scaffolds, Ladders, Personal Fall Protection, Designated Areas, etc.), and
  • Training.

What must employees be trained on?

Employers must train—and retrain when necessary—employees on the fall protection systems and equipment they use, including:

Training must be done by a qualified person.

To learn more about who is considered a qualified trainer and how to comply with the OSHA Walking-Working Surfaces regulations, check out the Walking Working Surfaces: What You Need to Know for Supervisors and Employees training program.

What specific training is required for high hazard and employees requiring fall protection?

Required training is task- and equipment-specific for any employee who uses fall protection or equipment specified under Subpart D. For example, a worker who uses a fixed ladder must be trained on how to use the personal fall protection system required when climbing the ladder, as well as safe climbing techniques.

When must employers comply?

The majority of the new requirements under Subpart D are effective January 17, 2017; however, OSHA has extended the compliance dates for a few requirements as specified in the following table:

Subpart D Section Compliance Date
§1910.30(a) and (b) – Deadline by which employers must train employees on fall and equipment hazards May 17, 2017
§1910.27(b)(1) – Certification of anchorages November 20, 2017
§1910.28(b)(9)(i)(A) – Deadline by which employers must equip existing fixed ladders with a cage, well, ladder safety system, or personal fall arrest system November 19, 2018
§1910.28(b)(9)(i)(B) – Deadline by which employers must begin equipping new fixed ladders with a ladder safety system or personal fall arrest system November 19, 2018
§1910.28(b)(9)(i)(D) – Deadline by which all fixed ladders must be equipped with a ladder safety system or personal fall arrest system November 18, 2036