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

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 OSHA’s standards for walking and working surfaces apply to all permanent places of employment with some exceptions

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.

Subpart D 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 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

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 Surface conditions: All places of employment are to be kept clean and orderly, and in a sanitary condition. Clean and, so far as possible, dry condition. Designed, constructed and maintained free of recognized hazards Application of loads. Designed, constructed, and maintained to support their maximum Intended load; and Not loaded beyond their maximum intended load. Access and egress. Maintenance and repair. Regular and periodic inspection and maintenance The hazard must be guarded to prevent employee use if not immediately corrected. Where conditions may affect the structural integrity of the walking-working surface, a qualified person must perform or supervise the maintenance or repair of that surface.

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.

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.

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

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.

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

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

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.

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 1:4 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

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.

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

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

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

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.

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.

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

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

Training Requirements Fall hazards Equipment hazards Retraining Training must be understandable

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 Rolling stock – presently does not address fall protection on rolling stock. Clarification , should it be excluded, what are employers doing now, how are the employees protected. Will not cover the protection in “railroad operations”. Steel erection and pre cast its concrete. Should a qualified climber be left in for outdoor billboard companies. There are no current provisions for the requirements of rope descent systems other than they must be sound. fall protection requirements are found in proposed subpart I. New dual-mode self retracting lanyards that lower the person for rescue after the fall.

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 cleaner’s positioning systems

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

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.

Coefficient of Friction COF 0.5 value Letter of Interpretation can be found at: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24511 Current consensus flooring standard ANSI/NFSI - B101.0 – B101.8 https://nfsi.org/ansinfsi-standards/standards/

Additional References Proposed 2010 Subparts D and I - https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=21518 Safety and Health Topics Page – Walking / Working Surfaces - https://www.osha.gov/SLTC/walkingworkingsurfaces/index.html