By Evan Gurley
Maintaining order throughout the day requires a great deal of planning and management.
Housekeeping is not just about cleanliness. It includes keeping work areas neat and orderly and keeping aisles, floors and stairs free from slip and trip hazards. In addition, good housekeeping promotes a safer, more efficient work environment. And maintaining order throughout the day requires a great deal of planning and management. To help precasters and other manufacturers maintain good housekeeping practices in the plant, the Occupational Safety and Health Administration has revised and updated its general industry standards on walking-working surfaces.
According to OSHA, falls from heights are the No. 1 leading cause of serious work-related injuries and deaths. On average, more than 200,000 serious injuries and 345 fatalities occur annually among workers directly affected by the final standard.
What is included in the final rule?
The final rule covers all general industry walking-working surfaces, including but not limited to, floors, ladders, stairways, runways, scaffolds, elevated work surfaces and walkways. To protect workers from hazards associated with those surfaces, the final rule updates and revises general industry standards (29 CFR part 1910, subpart D).
Also included in the rule are revised and new provisions that address fixed ladders, rope descent systems, fall protection systems and helpful criteria on personal fall protection systems and training. In addition, the final rule adds new requirements on the design, performance and use of personal fall protection systems to the general industry personal protective equipment standards (29 CFR part 1910, subpart I).
The final rule increases consistency between general industry and construction standards, which will make compliance easier for employers who conduct operations in both. The rule updates requirements to reflect advances in technology, creating consistency with recent OSHA and national consensus standards. The final rule also uses performance-based language whenever possible to give employers greater compliance flexibility. OSHA estimates the final standard rule will prevent 29 fatalities and 5,842 injuries each year.
The final rule went into effect on Jan. 17, 2017. Most of the requirements in the final rule are existing provisions that OSHA is retaining and updating. OSHA believes that employers are already in compliance with those provisions and, therefore, it is not necessary to provide additional time to comply with them.
The extended compliance dates give employers time to get familiar with the new requirements, evaluate changes they may need to make, purchase equipment necessary to comply with the final rule and develop and present required training. The compliance date for the required training component was May 17, 2017.
In addition to the compliance dates, OSHA also has developed training requirements to ensure workers who use personal fall protection are trained and retrained as necessary about fall and equipment hazards, including fall protection systems.
A qualified person must train workers to correctly:
- Identify and minimize fall hazards
- Use personal fall protection systems and rope descent systems
- Maintain, inspect and store equipment or systems used for fall protection
Situations requiring retraining of employees include, but are not limited to:
- When changes in the workplace render previous training obsolete or inadequate
- When changes in the types of fall protection systems or equipment to be used render previous training obsolete or inadequate
- When an affected employee’s knowledge or use of fall protection systems or equipment indicate that the employee no longer has the understanding or skill necessary to use equipment to perform the job safely
The final rule defines “walking-working surfaces” as any surface on or through which an employee walks, works, or gains access to a work area or workplace location. Below are the most notable changes to the OSHA regulation and how these changes will impact the precast concrete industry.
Ladder safety requirements
Falls from ladders account for 20% of all fatal and lost-work-day injuries in general industry. The new rule includes requirements to protect workers from falling off platforms, portable ladders, mobile ladders and fixed ladders.
The following ladder requirements are part of the new rule:
- Each ladder must be inspected before initial use in a work shift to identify defects.
- Ladders must be capable of supporting the maximum intended load.
- Mobile ladder stands and platforms must be capable of supporting four times the maximum intended load.
- Fixed ladders (ladders permanently attached to a structure, building, or equipment, excluding manhole steps) that extend more than 24 feet require that employers have ladder safety or personal fall arrest systems. This rule phases out the use of cages or wells for fall protection. Within 20 years, all ladders extending more than 24 feet must have ladder safety or personal fall arrest systems.
- Under the revisions for portable ladders, employers must ensure that:
- Rungs and steps are slip-resistant.
- Portable ladders used on slippery surfaces are secured and stabilized.
- Portable ladders are not moved, shifted or extended while a worker is on them.
- Top steps and caps on stepladders are not used as steps.
- Ladders are not fastened together to provide added length unless designed for such use.
- Ladders are not placed on boxes, barrels or other unstable bases to obtain added height.
The new rule also includes requirements for protecting employees in general industry from falling objects. When employees are exposed to falling object hazards, the employer must ensure each employee is provided with and wears compliant head protection.
Employers must also implement one or more of the following:
- Erect toe boards, screens or guardrails to prevent objects from falling
- Erect canopy structures
- Barricade areas where objects have fallen and prohibit workers from entering
Fall protection options
Employers must continue to protect workers from fall hazards along unprotected sides or edges that are at least 4 feet above a lower level. The new revisions set requirements for fall protection in specific situations and establish requirements for the performance, inspection, use and maintenance of personal fall protection systems.
Under the rule, OSHA states that employers may choose from the following fall protection options:
- Guardrail system
- Safety net system
- Personal fall arrest system
- Positioning system
- Travel restraint system
- Ladder safety system (cages and wells are not included)
Rope descent system
Although most precasters will never encounter a situation where rope descent systems are used, OSHA has updated the rule to include a 300-foot height limit and requires building owners to affirm in writing that the anchorages used for the RDS have been tested, certified and maintained to support a maximum of 5,000 pounds for each worker attached.
How precasters are addressing the new rule
Since the new rule requires employers to ensure working surfaces are kept in a clean, orderly condition, some precasters are making changes now to achieve compliance.
Ruben Gallegos, safety manager at Jensen Precast – Fontana, Calif., stated his company is making several changes.
“We implemented a program that QC inspectors will not sign off on a pre-pour or post-pour ticket unless the catwalk is free of debris such as terminators, hammers, etc.,” Gallegos said. “The program is working great.”
Gallegos added that to keep general work areas clean, the 5S Lean Manufacturing program will be implemented throughout the plant.
“The difference is awesome – less slip and trip hazards,” he said. “All areas will be inspected monthly by me.”
Review current company policies for changes
The updated language in the new rule brings several changes to both the employer and employees in the precast concrete industry. Employers have more flexible options for selecting fall protection and employees will be better protected. Precasters must take a close look at their current operations to see if and how changes will affect them and address any possible non-compliance concerns.
Evan Gurley is a technical services engineer with NPCA.
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