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Seven Million Ways to Prevent Injuries

Seven Million Ways to Prevent Injuries

OSHA's new take on the Walking-Working Surfaces and Fall Protection standard is causing companies in general industry to re-evaluate safety plans for slip, trip and fall prevention.

Decades after OSHA first held a public meeting regarding revisions to its Walking-Working Surfaces standard for general industry, the final rule will become effective on Jan. 17.

The revision to 29 CFR Part 1910 general industry addresses subpart D – for slip, trip and fall hazards and subpart I – adding requirements for personal fall protection systems. In addition, it eliminates the existing mandate to use guardrails as a primary fall protection method and allows employers to choose from accepted fall protection systems, according to OSHA.

"The final rule will increase workplace protection from those hazards, especially fall hazards, which are a leading cause of worker deaths and injuries," Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels previously said to the press. "OSHA believes advances in technology and greater flexibility will reduce worker deaths and injuries from falls."

OSHA estimates the new standard will prevent 29 fatalities and more than 5,842 injuries annually. The rule will affect about 112 million workers at 7 million worksites.

To say the final rule is long-anticipated is an understatement. Subparts D and I originally were appended to 29 CFE Part 1910 in 1971. After a series of informal public meetings and extensive research was conducted, the agency published a first round of proposals to revise the subparts in April 1990 and again sought feedback in 2003 and 2010. It wasn't until November 2016 that the final rule was released.

As proposed rules have been introduced throughout the years, employers and safety managers already have steadily integrated personal fall protection that meets or exceeds the new standard, meaning it will have minimal-to-no impact on those operations. However, others are still evaluating how they will revise their current safety plans to accommodate the changes.

Adapting to Change

OSHA's fall protection requirements for general industry now will fall in more closely with construction standards,  accommodating outdated scaffolding standards and allowing companies to select the best personal protective equipment for their specific situation. For some safety managers, this means business as usual, but for others, equipment updates and training will need to be evaluated.

Joann DeLao, safety manager at Hunter Site Services, an America's Safest Company, anticipates no change to the company's program with the new rule.

"Hunter Site Services already has an extensive fall protection program utilizing personal fall protection – 100 percent tie off and 100 percent ladder tie offs," she says.

As far as equipment upgrades, the company already had been looking to a ladder safety system prior to the new rule being released, she said. In addition, in-house training and hazard recognition already were part of the company's safety plans.

In the Southwest, despite more favorable weather conditions, slips, trips and falls still are an integral part of safety plans.

Nathan Cashion, safety supervisor, South Texas Project Nuclear Operating Co. (STPNOC), an America's Safest Company, is in the gap analysis phase to determine how much the company will need to revise its hazard recognition and injury prevention methods to comply with subparts D and I.

Cashion notes five prevention methods in STPNOC's latest safety plan that are employed to reduce same-level slips, trips and falls at the company:

  1.  Situational awareness.
    • Keep travel paths, walkways and stairs clear of parts and materials.
    • Elevate or cover hoses, cords and leads to eliminate tripping hazards.
    • Prior to using a harness, lanyards and safety lines, the user shall perform an inspection for signs of cuts, fraying, in-service loading or other damage that may cause failure during use.
  2. Placement of signage when slip hazard is present.
  3. Anti-skid material in known slip areas.
  4. Housekeeping efforts.
  5. Floor coatings in the turbine and reactor containment building.

Other companies such as South Dakota Wheat Growers (SDWG), another America's Safest Company, progressively will incorporate equipment and training into their safety plans as OSHA's timeline dictates.

"The new standards will have some effect on our company as new equipment is added or replaced in the future," says Tom Waletich, EHS specialist, SDWG.

Because the company operates in the Midwest, the hazards associated with slips and falls are a constant battle, especially in the winter months, he says.

Currently, all employees receive training on the hazards of slip, trip and falls prior to beginning work and on an annual basis going forward. Facilities are prepared through regular inspections of work areas and housekeeping in any areas where work traffic is identified.

"Our current winter weather conditions bring us many slip hazards, and our employees are prepared through ongoing safety communications (two-minute safety talks), additional footwear protection and the use of ice-melt in traffic areas," Waletich says. "Our company also incorporates a behavioral based safety program in which employees observe each other completing tasks and communicate positive feedback to enhance safety awareness which includes slip, trip and fall hazards."

From Old to New

Even though the Walking-Working Surfaces final rule has been established and released before a change in administration, the Congressional Review Act potentially could reverse some or all of the provisions that OSHA has required of employers.

"It is worth bearing in mind that OSHA's rule flouts recent Republican warnings to President Obama that no new final rules should be released in the wake of the election results," Beveridge & Diamond P.C. opined in a recent newsletter. "Thus, although its substance has generated less controversy than many other rules adopted under the Obama administration, OSHA's new rule faces an uncertain trajectory."

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