There have been recent changes to the General Industry “Walking-Working Surfaces” (W-W S) regulations. What some refer to as Subpart D of the law is also more commonly referred to as Slips, Trips and Falls. The main reason for change was due to so many workplace injuries and fatalities being attributed to the hazards in the W-W S areas. Year after year, Department of Labor accident statistics rank W-W S injuries and fatalities at the top of their list. The distant second place reason for the changes was to better align the ambiguous 1910 General Industry antiquated version to the more definitive 1926 Construction Subpart M standard. Bottom line for employers, the General Industry regulations have now caught up to the Construction regulations in most areas. What once provided very little in the way of a clear concise written requirement has now been revised to be fairly straight forward and easier to understand. The regulation is now more of a “performance” standard where by the employer has now been given the flexibility to implement his own safety program incorporating the new rules.
Stairs, ladders, aisles, roofs, anchorage points, unprotected edges (like dock boards and/or loading docks)…. just to name a few of the areas affected by the rule changes. But to me the biggest change was to fall protection and personal fall protection. Yes, there is a difference. Fall protection means, among other things, guard rails. Some people call them standard rails. Not wanting to get into the weeds….but gone are the old top rail distances, replaced by a new top rail height of 42 inches +/_ 3 inches. And don’t look for any letters of interpretation on the minimum 36 inch height rule….they have been rescinded. Back to the biggest change. Personal fall protection is just that…personal. This includes body harnesses, lanyards, the aforementioned anchorage points or tie off points and lifelines. You need to be now aware of what training program you need to have for all associates using this equipment. And it better be by a “qualified” person too. There’s now an actual definition in Section 21 that tells you what qualified means. Additionally about your training program, it better mention “inspection” of equipment prior to use too. OSHA was so serious about both personal fall protection (PPE) and training that they gave them both a new separate Section in the standard which are Section 140 for fall protection PPE and Section 30 for Training.
The upcoming BRSA conference on April 6th will attempt to address many of these changes in more details. Better get to our website and register.