Subparts D Walking/Working Surfaces

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Subparts D Walking/Working Surfaces
PRESENTED BY Joan M. Spencer Compliance
Assistance Specialist Tampa Area Office
813-626-1177 spencer.joan_at_dol.gov
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Introduction

• Slips, trips and falls
• Accounted for 27 percent of cases involving days
  away from work in 2014.
• 17 percent of all workplace deaths
• Falls on same level have increase since 2012
• OSHAs standards for walking and working surfaces
  apply to all permanent places of employment with
  some exceptions

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Federal Register

• Published on May 24, 2010.
• Was expected to be released as a final rule
  sometime in 2015.
• But, now put on hold.
• Estimated to prevent 20 deaths and more than
  3,500 lost-time injuries annually.

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Subpart D

• Proposed
• 1910.21 Scope, application and definitions
• 1910.22 - General requirements
• 1910.23 - Ladders
• 1910.24 - Step bolts manhole steps
• 1910.25 - Stairways
• 1910.26 - Dockboards
• 1910.27 - Scaffolds (including rope descent
  systems)
• 1910.28 - Duty of have fall protection
• 1910.29 - Fall protection systems criteria and
  practices
• 1910.30 - Training requirements

• Current
• 1910.21 - Definitions
• 1910.22 - General requirements
• 1910.23 - Guarding floor and wall openings and
  holes
• 1910.24 - Fixed industrial stairs
• 1910.25 - Portable wood ladders
• 1910.26 - Portable metal ladders
• 1910.27 - Fixed ladders
• 1910.28 - Safety requirements for scaffolding
  related topic page
• 1910.29 - Manually propelled mobile ladder stands
  and scaffolds (towers)
• 1910.30 - Other working surfaces

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General Requirements

• Must be kept clean, orderly and sanitary.
• Floors kept clean and dry as best as possible.
• Kept free from protruding nails, splinters,
  holes, or loose boards.
• Safe clearances around mechanical handling
• Permanent aisles and passageways shall be
  appropriately marked.
• Covers and/or guardrails provided to protect
  personnel from open pits, tanks, vats, ditches.
• Floor loading protection

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Guarding Floor and Wall Openings and Holes

• Floor openings
• standard railing
• a hinged floor opening cover and removable
  standard railings on all exposed sides
• Ladderway floor opening or platform
• standard railing with standard toeboard with the
  passage through the railing by a swinging gate or
  offset
• Other floor openings, e.g. hatchway, skylight,
  pit, trapdoor, manhole, temporary floor holes,
  doors opening to stairs, etc.

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Guarding Floor and Wall Openings and Holes

• Every wall opening from which there is a drop of
  more than 4 feet
• Rail, roller, picket fence, half door, or
  equivalent barrier.
• Toe boards
• Grab handles for material handling
• Other wall openings, e.g. extension platform,
  chutes, window wall opening, temporary wall
  opening, etc.

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Guarding Floor and Wall Openings and Holes

• Every open-sided floor or platform 4 feet or more
  above adjacent floor or ground level
• standard railing on all open sides except where
  there is entrance to a ramp, stairway, or fixed
  ladder.
• Possible toe boards
• Dangerous equipment or processes protection
  regardless of height

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Guarding Floor and Wall Openings and Holes

• Stairway railings and guards
• Stairs with four or more risers shall be equipped
  with standard stair railings or standard
  handrails
• Rails dependent on the width of the stair
• Railing, toe boards, and cover specifications
• Consist of top rail, intermediate rail, and
  posts, and a vertical height of 42 inches
• Stair railing vertical height - not more than 34
  inches nor less than 30 inches
• 4 toe boards
• capable of withstanding a load of at least 200
  pounds applied in any direction at any point on
  the top rail.

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Fixed Industrial Stairs

• Required for regular travel
• Interior or exterior stairs except fire escapes
• Angles to the horizontal of between 30 and 50
  degrees
• Treads must be slip resistant with uniform rise
  height and tread width
• Must be able to carry 5 times expected load
  minimum of 1000 pounds
• Minimum width of 22 inches

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Portable Wood/Metal Ladders

• Maximum length
• stepladders 20 ft.
• single ladders 30 ft.
• two-section rung ladders 60 ft.
• Stepladders must be equipped with a metal
  spreader or locking device
• Inspected periodically
• Kept in good condition at all times

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Portable Wood/Metal Ladders

• Free from sharp edges, splinters, oil grease, or
  other defects which would affect their use.
• Always place the ladder on secure footing and
  lock in place.
• Do not splice shorter ladders together to make
  long ladders.
• The top of a regular stepladder shall not be used
  as a step.
• Always face the ladder when climbing or
  descending.

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Portable Wood/Metal Ladders

• Ladders used to gain access to a roof or other
  area must extend at least 3 feet above the point
  of support (length dependent)
• Use at a 14 ratio
• Withdraw defective ladders from service and tag
  or mark "Dangerous, Do Not Use
• Never use ladders in a horizontal position as
  scaffolds or work platforms
• Never use metal ladders near electrical equipment

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Fixed Ladders

• Minimum design live load shall be a single
  concentrated load of 200 pounds proposed at 250
  pounds
• Grandfathered
• Proposed Fixed ladders must be capable of
  supporting two live loads of at least 250 pounds
  each, concentrated between any two consecutive
  attachments, plus anticipated loads e.g. ice
  buildup, impact loads resulting from the use of
  ladder safety systems. The number and position of
  additional concentrated live loads must also be
  included.

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Fixed Ladders

• Permanently attached to a structure, building or
  equipment
• Cages or wells required if longer than 20 ft.. to
  a maximum unbroken length of 30 ft..
• Ladder safety devices may be used on tower, water
  tank and chimney ladders over 20 ft.. in unbroken
  length instead of cage protection

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Fixed Ladders

• All fixed ladders must be inspected regularly and
  be maintained in a safe condition.
• Preferred pitch in range of 75 to 90 degrees with
  horizontal.
• Clearance from steps and rungs, or grab bars, or
  both, to the nearest permanent object in back of
  the ladder must be 7 inches

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Scaffolding

• Must be capable of supporting four times the
  maximum intended load
• Do not alter or move while in use
• Protect workers on scaffolds from overhead
  hazards
• If higher than 10 ft.., use guardrails, midrails
  and toeboards
• Use wire mesh between the toeboard and guardrail
  if people work or pass underneath
• Must be equipped with access ladder or equivalent

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Scaffolds

• Proposed must meet the requirements of 29 CFR
  1926 -Subpart L (1926.450-454) with exception of
  rope descent systems
• Rope descent system means a suspension device
  that supports one employee in a chair (seat
  board) and allows the user to descend in a
  controlled manner and to stop at any time at a
  desired level of descent. A rope descent system
  is a variation of the single-point adjustable
  suspension scaffold. Also known as a controlled
  descent device, controlled descent equipment, or
  controlled descent apparatus.

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Duty to have fall protection

• Proposed 1910.28 - sets requirements for
  employers to provide fall protection.
• All fall protection must conform to the criteria
  set forth in proposed 1910.29, except that
  personal fall protection systems (for example,
  personal fall arrest systems, restraint systems,
  and positioning device systems) must conform to
  the criteria set forth in subpart I of this part.

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Fall Protection Systems Criteria and Practices

• Guardrail systems
• Safety net systems
• Designated areas, a distinct portion of a
  walking-working surface delineated by a perimeter
  warning line in which temporary work may be
  performed without additional fall protection.
• Covers
• Handrail and stair rail systems

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Fall Protection Systems Criteria and Practices

• Cages, wells and platforms used with fixed
  ladders
• Qualified climbers, only for outdoor advertising
  operations
• Ladder safety systems
• Personal fall protection systems
• Protection from falling objects
• Grab handles

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Training Requirements

• Fall hazards
• Equipment hazards
• Retraining
• Training must be understandable

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Other Specific Issues

• Fall protection on rolling stock and motor
  vehicles
• Fall protection on stacked material
• Qualified climber
• Building anchorage for rope descent systems
• Technological advances in fall protection and
  fall arrest

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Subpart I

• Section-
• 1910.140, Personal fall protection systems
• Scope and application
• Definitions
• General requirements
• Personal fall arrest systems
• Positioning systems, includes a section on window
  cleaners positioning systems

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Subpart I - PPE

• Addition of
• 1910.140 Fall Protection System
• Appendix C - Personal Fall Protection Systems -
  non-mandatory
• Appendix D Test Method and Procedures for
  Personal Fall Protection Systems non-mandatory

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Example of Text For 5(a)(1) Citation for
Fiberglass Ladder

• Section 5(a)(1) of the Occupational Safety and
  Health Act of 1970 The employer did not furnish
  employment and a place of employment which were
  free from recognized hazards that were causing or
  likely to cause death or serious physical harm to
  employees in that employees were exposed to fall
  hazards a) XYZ Inc., Warehouse - On or about
  December 10, 2015, the employer failed to ensure
  all ladders, such as a ABC Co. fiberglass
  extension ladder, were used in accordance with
  the safety instructions of the manufacturer's
  label. The employer failed to use the ladder in
  accordance with the posted safety instructions
  such as a) This ladder section is not designed
  for separate use, b) When use is required on a
  slippery surface secure ladder from excessive
  movement, c) Always face ladder and maintain a
  firm grip while on it, d) Never climb or stand
  higher than 3 feet from the top of the ladder, e)
  When possible, have someone hold the ladder, f)
  For additional care, use and safety instructions,
  contact your employer, dealer or manufacturer, or
  see ANSI A14 Standards (see other labels),
  American National Standard for Ladders Portable
  Reinforced Plastic Safety Requirements (ANSI ASC)
  A14.5-2007. 9.3.4 Footing Support. Devices such
  as shoes, spurs, spikes, combinations thereof, or
  similar devices of substantial design should be
  installed where required for slip resistance and
  bearing area. Ladders shall not be used on ice,
  snow, or slippery surfaces unless suitable means
  to prevent slipping are employed.

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Coefficient of Friction

• COF 0.5 value
• Letter of Interpretation can be found at
• https//www.osha.gov/pls/oshaweb/owadisp.show_docu
  ment?p_tableINTERPRETATIONSp_id24511
• Current consensus flooring standard ANSI/NFSI -
  B101.0 B101.8
• https//nfsi.org/ansinfsi-standards/standards/

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Additional References

• Proposed 2010 Subparts D and I -
  https//www.osha.gov/pls/oshaweb/owadisp.show_docu
  ment?p_tableFEDERAL_REGISTERp_id21518
• Safety and Health Topics Page Walking / Working
  Surfaces - https//www.osha.gov/SLTC/walkingworkin
  gsurfaces/index.html