Fall Protection Training Updated to Comply with New Changes to OSHA Walking-Working Surfaces Rule

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As you may know, OSHA recently finalized a rule to update their Walking-Working Surfaces standard and their Fall Protection standard. In particular, the new rule updates standards addressing slip, trip, and fall hazards in Subpart D and adds additional requirements for personal fall protection systems in Subpart I.

In this article, we’ll point out some of the major changes that affect fall prevention and protection training. We’ll look at other consequences of the changes in future articles as well. In doing so, we’ll demonstrate how we’ve changed our own online Fall Prevention and Protection course to match the new final rule.

In addition to all that, we’ll give you some additional useful information too, such as what the purpose of the new rule is, how employers will benefit from it, and information about effective dates.

Who And What Do the Walking-Working Surfaces Rule Changes Affect?

The new final rule for walking-working surfaces applies to all general industry workplaces. This includes many different types of workplaces, including building management services, utilities, warehouses, retail, window cleaning, chimney sweeping, and outdoor advertising.

The new rule covers all walking-working surfaces. This includes floors, stairs, roofs, ladders, ramps, scaffolds, elevated walkways, and fall protection systems. As OSHA puts it, any “horizontal and vertical” walking surface.

As you can see from the list immediately above, the new rule will affect quite a number of different potential hazards at work and will call for you to modify several different parts of your safety training program. In this article, we’re focusing on changes to fall prevention & protection training, and we’re using our own online fall prevention and protection course to illustrate some of the changes we made, but we’ve also changed the following courses to match:

What Major Changes Did OSHA Make to the Walking-Working Surfaces and Fall Protection Standards?

Speaking of the changes, what are the major ones?

Below is a list created by OSHA that identifies the major changes. We’re going to briefly explain each item, but for more specifics about each of these changes please see OSHA’s FAQ page on this rule change.

  • Fall protection flexibility (§1910.28(b)).  Eliminates former requirement that guard rails be primary fall protection method and gives employers the freedom to choose from a range of fall protection systems based on the job and circumstances. Also allows for non-conventional fall protection in certain situations, such as temporary work on low-slope roofs and working on residential roofs when other methods aren’t feasible or might commit a hazard.
  • Updated scaffold requirements (§1910.27(a)).  Replaces older general industry scaffolding standard in favor of having general industry employers comply with OSHA construction scaffolding standard.
  • Phase-in of ladder safety systems or personal fall arrest systems on fixed ladders (§1910.28(b)(9)).  Begins a 20-year phase-in to equip fixed ladders that extend over 24 feet with ladder safety or personal fall arrest systems and that prohibits cages and wells as a means of fall protection (after the phase-in deadline). Cages and wells on existing ladders are grandfathered in.
  • Phase-out of the “qualified climber” exception in outdoor advertising (§1910.28(b)(10)).  Phases out an OSHA directive that allowed qualified climbers in outdoor advertising to climb fixed ladders on billboards without fall protection. Phases in the requirement to equip fixed ladders that extend over 24 feet with ladder safety or personal fall arrest systems.
  • Rope descent systems (RDS) and certification of anchorages (§1910.27(b)).  Codifies an OSHA memorandum for employers who use rope descent systems (RDSs) to perform elevated work. The final rule prohibits employers from using an RDS at heights greater than 300 feet (with feasibility/hazard creation exceptions), and includes requirements about inspection, testing, certification, and maintenance of permanent anchorages that are capable of supporting at least 5,000 pounds per employee attached.
  • Personal fall protection system performance and use requirements (§1910.140).  Adds requirements on the performance, inspection, use, and maintenance of personal fall arrest systems.  Prohibits the use of body belts as part of a personal fall arrest system, as was already true for construction.
  • Inspection of walking-working surfaces (§1910.22(d)).  Requires that employers inspect walking-working surfaces regularly and as needed and correct, repair, or guard against hazardous conditions; and
  • Training (§1910.30).  Adds requirements that employers ensure workers who use personal fall protection and work in other specified high hazard situations are trained, and retrained as necessary, about fall and equipment hazards, including fall protection systems.  Employers must provide information and training to each worker in a manner the worker understands.

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Are There New Training Requirements for Fall Prevention & Protection and When Do They Become Effective?

Since we’re looking at changes to Fall Prevention Training in this article, those are good questions.

Here’s what the OSHA FAQ page for this rule change says about fall prevention training requirements:

Training (§1910.30).  The final rule adds requirements that employers ensure workers who use personal fall protection and work in other specified high hazard situations are trained, and retrained as necessary, about fall and equipment hazards, including fall protection systems.  Employers must provide information and training to each worker in a manner the worker understands.

According to OSHA, “The final rule becomes effective…60 days after publication in the Federal Register.”  The rule was published in the Federal Register on November 18, 2016,  In addition, “OSHA also provides delayed or phased-in compliance dates for several requirements in the final rule, including…training workers on fall and equipment hazards–6 months.”

I attended a fall prevention & protection course put on by  the Pacific Northwest OSHA Education Center (this is part of the University of Washington’s School of Public Health Department of Environmental Occupational & Health Safety. The class was led by the excellent instructor Harvey McGill, and he explained the training-related deadlines this way:

  • May 17, 2017–train employees on fall and equipment hazards
  • July 17, 2017–ensure exposed workers are trained on fall hazards
  • July 17, 2017–ensure workers who use equipment covered by the final rule are trained

Here’s how we explain the training requirement in our own fall prevention and protection course.

Changes to Fall Prevention Training

Using the list from OSHA above, you can see you’d need to modify your previous fall prevention training, including modifications to match the following “big changes” listed by OSHA:

New Fall Prevention Training Topic 1: Fall protection flexibility (§1910.28(b))

You’d want to mention the change away from an exclusive mandate on guard rails as the primary fall protection method and the new flexible options to select from a range of accepted fall protection systems, including personal fall protection systems.

Here’s how we address that in our course:

And here’s OSHA’s full notes on this on their FAQ page:

The final rule allows employers to protect workers from falls by choosing from a range of accepted fall protection systems, including personal fall protection systems. It eliminates the existing mandate to use guardrails as the primary fall protection method and gives employers the flexibility to determine what method they believe will work best in their particular workplace situation.  This approach has been successful in the construction industry since 1994.   The final rule allows employers to use non-conventional fall protection practices in certain situations, such as designated areas on low-slope roofs for work that is temporary and infrequent and fall protection plans on residential roofs when employers demonstrate guardrail, safety net, or personal fall protection systems are not feasible or create a greater hazard (§1910.28(b)(1) and (b)(13)).

New Fall Prevention Training Topic 2: Phase-in of ladder safety systems or personal fall arrest systems on fixed ladders (§1910.28(b)(9))

You’ll also want to explain the requirement to use personal fall arrest systems or ladder safety systems on fixed ladders of more than 24 feet.

Here’s how we explained ladder safety systems in our course:

And here’s OSHA’s full notes on this on their FAQ page:

The final rule phases in over 20 years a requirement to equip fixed ladders (that extend over 24 feet) with ladder safety or personal fall arrest systems and prohibits the use of cages and wells as a means of fall protection after the phase-in deadline.  There is wide recognition that cages and wells do not prevent workers from falling from fixed ladders or protect them from injury if a fall occurs.  The final rule grandfathers in cages and wells on existing ladders, but requires during the phase-in period that employers equip new ladders and replacement ladders/ladder sections with ladder safety or personal fall arrest systems.

New Fall Prevention Training Topic 3: Personal fall protection system performance and use requirements (§1910.140).

You’ll also want to address the new requirements for performance, inspection, use, and maintenance of personal fall protection systems.

Here’s how we covered inspection issues in our own course (this is one of two slides devoted to inspection in our course):

And here’s OSHA’s full notes on this on their FAQ page:

The final rule, which allows employers to use personal fall protection systems (i.e., personal fall arrest, travel restraint, and positioning systems), adds requirements on the performance, inspection, use, and maintenance of these systems.  Like OSHA’s construction standards, the final rule prohibits the use of body belts as part of a personal fall arrest system.

Additional Fall Prevention Training Topics for More Special Circumstances

We didn’t address the following points in our own course because they’re not widely relevant to our customer base, but if your employees are working on billboards and/or using rope descent systems, you’ll want to address these issues as well.

Phase-out of the “qualified climber” exception in outdoor advertising (§1910.28(b)(10)). 

Here’s how OSHA explains this in their FAQ page:

The final rule phases out OSHA’s directive allowing qualified climbers in outdoor advertising to climb fixed ladders on billboards without fall protection and phases in the requirement to equip fixed ladders (over 24 feet) with ladder safety or personal fall arrest systems.  Outdoor advertising employers must follow the fall protection phase-in timeline for fixed ladders.  However, if ladders do not have any fall protection, outdoor advertising employers have 2 years to comply with the existing standard (i.e., install a cage or well) or, instead, they may install a ladder safety or personal fall arrest system, both of which are cheaper than cages or wells;

Rope descent systems (RDS) and certification of anchorages (§1910.27(b)). 

Here’s how OSHA explains this in their FAQ page:

The final rule codifies OSHA’s memorandum for employers who use RDS to perform elevated work.  The final rule prohibits employers from using RDS at heights greater than 300 feet above grade unless they demonstrate it is not feasible or creates a greater hazard to use any other system above that height.  In addition, the final rule requires building owners to provide and employers to obtain information that permanent anchorages used with RDS have been inspected, tested, certified, and maintained as capable of supporting at least 5,000 pounds per employee attached.

Conclusion: Update Your Fall Prevention Training to Comply with OSHA’s New Rule Changes

We hope this helps give you a better idea of the recent final rule to update General Industry Walking-Working Surfaces and Fall Protection Standards in general, and in particular how to update your fall prevention training materials.

We plan on writing some similar articles to address changes to Ladder Safety training, Scaffolding training, Aerial Work Platform training, and Slip, Trip, and Fall training.

Until then, feel free to pick up a copy of our newly revised Fall Protection course or use the information above to modify your own training materials.

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Jeffrey Dalto

Jeffrey Dalto

Jeffrey Dalto is an Instructional Designer and the Senior Learning & Development Specialist at Convergence Training. Jeff has worked in education/training for more than twenty years and in safety training for more than ten. You can follow Jeff at LinkedIn as well.

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