With the implementation of many new federal rules delayed, under review, and even repealed by Congress, it’s easy to understand how employers could become lax about compliance with new requirements. But not all new rules are delayed or under review at this time, and affected employers should probably maintain an awareness of the rules whose provisions are still, to the best of anyone’s knowledge, being phased in as planned.
One such rule is the Occupational Safety and Health Administration’s (OSHA) new walking/working surfaces and fall protection rule, which was finalized in November 2016 and went into effect on January 17, 2017. The rule also included some phased-in provisions; one of those deadlines just passed, and others are coming up quickly as well.
Updated General Industry Fall Protection Requirements
The rule updated general industry standards to recognize technology advances and industry best practices, and it added new requirements for personal fall protection systems in general industry. It was also written with the intent to standardize fall protection requirements across general industry and construction and to give general industry employers greater flexibility in choosing fall protection methods.
Training Compliance Dates
Although the rule became effective on January 17, 2017, some provisions within the rule had later compliance deadlines. In particular, the compliance date for training was set for 6 months out—a deadline that just passed on May 17, 2017. By that date, employers were supposed to have trained exposed workers and workers who use equipment covered by the standard.
Training Requirements
The new training requirements are found in 20 CFR 1910.30 and specify that:
- Training must be conducted by a qualified person.
- Training must be provided to each employee in a manner that the employee understands.
The following topics must be covered, at a minimum:
- The nature of the fall hazards in the work area and how to recognize them;
- The procedures to be followed to minimize those hazards;
- The correct procedures for installing, inspecting, operating, maintaining, and disassembling the personal fall protection systems that the employee uses; and
- The correct use of personal fall protection systems and equipment, including proper hook-up, anchoring, tie-off techniques, and methods of equipment inspection and storage.
Additional topics for which workers may need training include:
- Dockboards. Workers who use dockboards must be trained in how to properly place and secure the dockboard to prevent unintentional movement.
- Rope descent systems. Workers who use rope descent systems must be trained in the proper rigging and use of the equipment as required by 29 CFR 1910.27.
- Designated areas. Employees who use a designated area must be trained in the proper set-up and use of the area.
Retraining requirements are similar to those found in other OSHA standards; workers must be retrained to keep up with changes in the workplace or the equipment they are using or whenever they appear to be using their equipment incorrectly.
Additional Compliance Dates
The compliance date for training has passed; if you have not trained workers, it’s time to get that done. Additional compliance dates that are still upcoming include:
- November 17, 2017: requirement for inspecting and certifying permanent anchorages for rope descent systems. Building owners must affirm in writing that permanent building anchorages used for rope descent systems have been tested, certified, and maintained as capable of supporting 5,000 pounds for each worker attached.
- November 17, 2018: requirement for installing personal fall-arrest or ladder safety systems on new fixed ladders over 24 feet (ft) and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures, and the requirement to ensure that existing fixed ladders over 24 ft, including those on outdoor advertising structures, are equipped with a cage, well, personal fall-arrest system, or ladder safety system.
- November 17, 2036: requirement for replacing cages and wells (used as fall protection) with ladder safety or personal fall-arrest systems on all fixed ladders over 24 ft.