Heightened OSHA protections are in effect. Are you in compliance?

June 16, 2017|Lisa Horn

OSHA updated regulations surrounding walking-working surfaces and fall protection systems, and these can be especially pertinent for manufacturers. Review details and applicable deadlines to ensure you are in compliance.

Your employees are the heart of your business. Keeping them safe should be at the core of operational excellence. At the most basic level, you need to ensure your safety systems are in compliance with regulatory standards, so take note of updated Occupational Safety and Health Administration (OSHA) requirements.

OSHA updated their requirements for walking and working surfaces and fall protection systems for general industry, which had not been updated since 1971. The new requirements address standards on slip, trip and fall hazards—the leading cause of worker deaths and lost-workday injuries. It does not affect construction or agricultural standards.

What has changed?

The final rule includes revisions in a number of areas and provides more consistency between general industry and construction industry standards—which may be a welcome change if you perform cross-industry activities. For detailed information, visit the OSHA website.

Fall protection

You must protect workers from fall hazards along unprotected sides or edges that are at least 4 feet above a lower level, as well as implement specific fall protection systems required in certain situations. OSHA provides a list of acceptable fall protection options, giving you the flexibility to choose the one that works best in a given situation and eliminating the requirement to use guardrails as the primary method. Like OSHA's construction standards, the standards also prohibit the use of body belts as part of a personal fall arrest system.

Rope descent systems

Rope descent systems (RDS) can only be used up to a 300-foot height limit, unless you demonstrate it is not feasible or it creates a greater hazard to use any other system above that height. Additionally, you must have written documentation that the permanent building anchorages used for RDS have been tested, certified and maintained appropriately.

Ladder safety requirements

New requirements were established to protect workers from falling off fixed and portable ladders, mobile ladder stands, and platforms. The ladders must be able to support their maximum intended load, while mobile ladder stands and platforms must be able to support four times their maximum intended load. Inspect ladders before their initial use during a work shift and identify any potential injury-causing defects. The new standards also:

  • Phase in a requirement that fixed ladders (over 24 feet) must be equipped with ladder safety or personal fall protection systems to prevent workers from falling or arresting their fall before contact with a lower level
  • Phase out the use of qualified climbers in outdoor advertising, thereby eliminating the hazard of workers climbing extended heights on fixed ladders without fall protection

Training and inspection requirements

A qualified person must train workers who use personal fall protection and work in other high hazard situations—and then retrain them as necessary—about fall and equipment hazards, including fall protection systems.

Inspect walking-working surfaces regularly and correct, repair or guard against hazardous conditions as needed.

Implementation guidelines and timeline

Most portions of the rule went into effect January 17, 2017, while others have delayed effective dates, including the following:

  • May 17, 2017: Train workers exposed to fall hazards and those using equipment noted in the updated standard, including fall protection systems and ladder systems
  • November 20, 2017: Inspect and certify permanent anchorages for rope descent systems
  • November 19, 2018: Install personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures
  • November 19, 2018: Ensure existing fixed ladders over 24 feet, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system or ladder safety system
  • November 18, 2036: Replace cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet

Remember, regulatory compliance is the foundation and most basic level of your safety system. Look beyond compliance requirements to develop a comprehensive safety system. Then take a big picture look at your operations to achieve overall operational excellence. An operational assessment is a great place to start. It includes a look at safety systems and then takes a deeper dive using outside eyes to find ways to make you efficient and profitable.

For more information about regulatory compliance, safety and how our Operations Consulting team can help you create operational excellence, please contact Lisa Horn, senior manager – operations consulting, at lisa.horn@schencksc.com or any of Schenck’s Operations Consulting team members.


Lisa Horn, senior manager – operations consulting, has nearly 20 years of experience leading continuous improvement initiatives in a variety of industries, including manufacturing. She advises senior leaders on strategy and aligns their vision, mission and goals to effectively execute plans that drive organizational success.