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OSHA Releases New Standard Interpretation on the Walking-Working Surfaces Rule

November 18, 2017

 

The U.S. Department of Labor's Occupational Safety and Health Administration issued a final rule updating its general industry Walking-Working Surfaces standards specific to slip, trip, and fall hazards in the last quarter of 2016 and which became effective in January 2017.

 

On August 17, 2017, the Occupational Safety and Health Administration (OSHA) released a letter issued to the Executive Director of the National Association of Tower Erectors (NATE), regarding implementation of the general industry Walking-Working Surfaces and Fall Protection Systems Rule. NATE asked for clarification on seven topics.

 

Topic 1 - Relates to the May 17, 2017 training deadline and the requirement for fall protection equipment

 

OSHA denied NATE's request for an extension and noted that the vast majority of NATE's workers would not require initial training due to the fact their employees previously received training on fall protections systems and fall hazards. In the preamble OSHA stated: “[a]n employer whose workers have received training, either from the employer or another employer, that meets the requirements of final §1910.30(a) will not need to provide additional initial training” (81 FR 82639). In addition, standards in place prior to the new standard required the use of fall protection equipment.

 

Topic 2 - Relates to the addition of fall protection to fixed ladders

 

OSHA denied the extension of the November 19, 2018 deadline for equipping existing fixed ladders (that extend more than 24 feet above a lower level) with some type of fall protection (i.e., cage, well, ladder safety system, personal fall arrest system). The denial is based on the fact previous standards required cages on ladders more than 20 feet above the ground.

 

Topic 3 - Relates to a request to exempt the tower industry from the 300-foot height limit for Rope Descent Systems (RDS)

 

 

OSHA denied the request, but stated that final rule provides that employers may use RDS above 300 feet if they demonstrate it is not feasible to access such heights by any other means or if those means pose a greater hazard than using an RDS (§1910.27(b)(2)(i)).

 

Topic 4 - Relates to a request to use 1,000 pound anchorage points versus the 5,000 pounds stated in the rule

 

OSHA stated that the final rule does not require a 5,000-pound anchorage point in every situation. An employer may use an anchorage that meets a different strength, provided that (1) the anchorage is part of a complete fall protection system, (2) the personal fall protection system maintains a safety factor of at least two, and (3) the anchorage is designed, installed, and used under the supervision of a qualified person (81 FR 82655).

 

 

Topic 5 - Relates to the request by NATE that the ANSI/ASSE Z359.1 – 2007 standard be used in place of the "Proof Test" requirement for gates

 

OSHA agreed with the request and will publish a technical amendment correcting §1910.140(c)(8) so it is consistent with the ANSI/ASSE standard.

 

Topic 6 - Relates to NATE's disagreement with the exemption for fall protection during pre-work and post-work inspections or assessments

 

OSHA denied the request noting that it made the rule consistent with OSHA’s Construction Fall Protection Standard (§1926.500(a)(1)) which is based on the premise that installing fall protection would take longer than conducting the inspection, exposing workers to fall hazards for a greater period of time and, thus, a greater hazard of falling.

 

Topic 7 - Relates to the request to change the height requirement from four to six feet to be consistent with OSHA’s construction industry fall protection standard

 

OSHA denied the request and stated that nothing in the rulemaking persuaded the Agency that adopting a fall protection trigger above four feet would provide equivalent or greater protection. The general industry standard’s fall protection trigger has been four feet since 1971 and it is consistent with the ANSI/ASSE standard. The new rule does not change the general industry standard’s fall protection trigger for consistency with the construction industry’s standard.

 

Please see the links below for additional information on this standard or to view our related training.

 

OSHA Interpretation ID:31373

 

29 CFR 1910.21 

 

Federal Register / Vol. 81, No. 223 / Friday, November 18, 2016

 

PSS Training for Organizations