OSHA’s standard on walking-working surfaces

Responding is Andy Olson, director of marketing, Rite-Hite Engineered Solutions, Rite-Hite Corp., Milwaukee.

Falls consistently rank as one of the most common causes of serious work-related injuries and fatalities, according to OSHA. The agency’s standard on walking-working surfaces for general industry (1910 Subpart D) was developed to help prevent dangerous falls from height or slips and trips on the same level (working surface).

Most of the rules within the regulation became effective in 2017, with several more phased in before 2019. Equipment standards on slip, trip and fall hazards hadn’t been revised since they were first adopted in 1971, so this was a necessary update.

One of the first portions of the regulation was ensuring proper training. When it comes to safety, training workers who are exposed to fall hazards or use equipment that can lead to a fall is essential. Although training has always been a requirement, the standard on walking-working surfaces reemphasized the need for ensuring safe practices.

Another element of the regulation allows employers more flexibility in choosing their own site-specific fall protection system. Safety managers can choose from several fall protection methods: guardrails, safety nets or personal fall arrest systems. This gives more responsibility to the safety manager, but also gives them the ability to choose the best safety option for their employees.

In instances in which guardrails are the preferred technique for preventing falls, facilities need to consider methods that comply with the walking-working surfaces standard in transfer areas. Dual reciprocating barriers are an excellent choice for meeting the OSHA regulation and providing safety for workers in controlled access areas on elevated surfaces because they allow access from only one side at a time.

Leading models of dual reciprocating barriers use a link bar design to ensure the inner gate works in tandem with the outer gate. When one side is open, the other side is closed; both can’t be open at the same time. For example, if a fork truck is lifting a pallet to the elevated platform, the outer gate will be open to receive it, while the inner gate closes to keep workers out. When the pallet has been safely placed in the control area, the inner gate can be opened by mezzanine-level workers, which simultaneously closes the outer gate.

The regulation also requires that barriers not be lower or deflect below 39 inches. For fixed barriers, a 39-inch height would be acceptable. However, there must be extra height added to barriers that deflect. This is key for retractable barriers, which are often used at loading docks that have an open dock policy and can expose employees to a fall of 4 feet or more out of the dock door.

Chains shouldn’t be used in this instance, as they aren’t strong enough to stop forklifts and typically sag well below the 39-inch requirement. It’s important for facility managers or safety managers to specify a retractable barrier that stretches across the entire width of the dock opening and can stop any forklift that might run into it.

It’s important for safety managers to continually review rules contained in the regulation on walking-working surfaces, as well as other fall hazard regulations, as they apply to any part of the facility where fall risks are present.

The information herein is provided as a general reference regarding the use of the applicable product(s) in specific applications. This information is provided without warranty. It is your responsibility to ensure that you are using all mentioned products properly in your specific application and in accordance with all laws and regulations.

Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.