The primary focus of OSHA's proposed Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) rule is the creation of a fall protection standard for general industry that is similar to the construction and maritime standards. But there also are some new rules for minimizing the likelihood of same-level slip, trip and fall incidents in facilities.
Originally proposed in 1990, then subsequently revised in 2003 and again in 2010, the final rule was scheduled for publication last month. Whether or not the final rule makes it into the Federal Register this year, the good housekeeping measures and other provisions in the most recent proposal can be implemented as best management practices to minimize same-level slip, trip and fall risks.
Currently, OSHA does not require facilities to have a written plan that specifically addresses floor safety risks. The most recent proposal does not require a specific written plan requirement either, but facilities will need to conduct periodic inspections and perform needed maintenance.
Identifying floor safety risks and establishing a specific plan to address them, or incorporating procedures to reduce floor safety risks into existing good housekeeping or other safety plans, can help ensure that the requirements of the new rule are being met.
Orderly and Sanitary
The proposed Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) rule begins with 29 CFR 1910.22(a)(1) remaining identical to the current regulation. This citation requires all areas of a facility to be maintained in a "clean and orderly and in a sanitary condition."
While it is not OSHA's intent that every inch of the workplace be held to cleanroom, food or pharmaceutical cleanliness standards at all times, it does mean that some level of housekeeping should be established and maintained. At a minimum, all floors and walkways should be unobstructed, doors and drawers kept closed and recognized hazards eliminated or guarded. Trash and other items that no longer are useful should be removed in a timely manner.
Clean and Dry
OSHA also doesn't expect every workplace floor to be perfectly clean and dry all of the time, but in general, floors shouldn't be dirty or wet. In areas where floors cannot regularly be kept clean and dry, the rule does allow for platforms, mats or other devices to be placed on floors to provide a safer walking surface.
Maintaining this provision solidifies OSHA's long-standing interpretation that the rule [29 CFR 1910.22(a)(2)] is "not limited to the hazards of slips, trips and falls, but also addresses any hazard that can be created when floors and work areas are not maintained in an orderly, clean, dry and sanitary condition."
Using mats or floor-level fans in building entrances and loading docks, and providing absorbent matting, anti-fatigue mats with drainage holes, mops or squeegees in production areas with overspray or near wet processes, are some ways to improve floor safety in areas that cannot be kept clean and dry.
Free of Hazards
The current requirement in 29 CFR 1910.22(a)(3) states that passageways are to be kept "free from protruding nails, splinters, holes or loose boards."
The proposed rule will be more encompassing and should open the door for safety professionals to have greater involvement during building design and construction phases, thereby potentially eliminating problems that inadvertently may be caused by choosing the wrong type of floor, floor covering or finish for a project. This paragraph now will require walking-working surfaces to be "designed, constructed and maintained free of recognized hazards that can result in death or serious injury to employees."
Incorporating floor safety into the design and construction phases makes sense, because it is far easier and less expensive to eliminate a problem before it happens. However, facilities traditionally spend far more time, money and effort in long-term maintenance of walking-working surfaces than they do designing or constructing them. The reason for this is that even the best flooring and construction products eventually age, fail or become more labor-intensive to maintain, which means that cleaning and preventive maintenance schedules for floors, sidewalks and parking lots may need to change over the life of each surface.
To meet the maintenance requirement, facilities will need to consider recognized floor safety hazards such as: uneven walking surfaces, crumbling sidewalks, potholes or deep large cracks, loose rugs, wet entrances and ice or snow in outdoor walking patch and parking lots. According to studies conducted by the National Floor Safety Institute, more than half of all slip, trip and fall injuries are caused by problems with the walking surface.
Recognizing potential floor safety risks and incorporating preventive maintenance and routine cleaning into facility maintenance and housekeeping plans will minimize the potential for injuries.
Maintenance and Repair
Proposed paragraph (d)(1) is an addition to the rule and reinforces the need to maintain and repair walking-working surfaces by requiring facilities to conduct "regular and periodic" inspections and make needed corrections. As proposed, there is no definition of "regular and periodic," so each facility will need to determine an inspection frequency that ensures floors and walkways are kept safe.
For some facilities, quarterly inspections may be frequent enough. For others, it may mean hourly inspections.
In some cases, frequency may vary depending upon the use of each space. For example, carpeted offices may only need to be inspected once a month or once a quarter. Production areas with wet or dirty processes may need a daily inspection. The frequency of inspections for entrances, lobbies and hallways may vary according to the season. Identifying potential floor safety risks for each area of your facility can be useful in determining necessary inspection frequencies.
As hazards are identified, proposed paragraph (d)(2) stipulates that they be corrected, repaired or guarded. Cleaning up a small spill immediately after it happens or replacing a saturated entrance mat with a dry one are two hazards that quickly can be corrected.
Other walkway problems, such as replacing a cracked flooring tile or fixing an uneven sidewalk, are examples of hazards that likely will take longer to repair or correct. Stocking barrier tape, safety cones or other similar devices are ways to guard floor safety hazards until they can be repaired.
It is very common to see "Caution: Slippery Floor" signs or traffic cones surrounding a pothole that are left in place for months or even years. The goal of this requirement is for problems to be corrected. Guarding should be viewed as temporary and as a way to minimize risk only until the problem can be fixed.
Repairing some walking-working surface hazards could affect the structural integrity of a surface. When this is the case, proposed paragraph (d)(3) requires that a qualified person perform or supervise the repair to ensure that the repair will not compromise the surface.
An example of this type of repair is resurfacing concrete. Resurfacing may be desirable to fill deep cracks, holes or uneven areas that present tripping hazards. However, this adversely could affect the load rating. A qualified person would be needed to determine how to reduce these risks without compromising the integrity of the floor.
The new rule will add training requirements to ensure employees can recognize fall hazards, know how to protect themselves against those hazards and be able to use any equipment that is provided. Although this requirement primarily addresses the need for training on the use of personal protective equipment provided to prevent falls from a height, the rule defines "fall hazards" as both falls from heights and falls to the same level.
Slips, trips and falls to the same level are the second leading cause of lost-work-time injuries – second only to sprains and strains. Identifying walking-working surface hazards, updating housekeeping plans and regularly maintaining, repairing and correcting problems will minimize the chance of slip, trip and fall incidents.
Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 100 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP,) Walkway Auditor Certificate Holder (WACH,) Community Emergency Response Team (CERT) trainer, hazmat technician, serves on the Blair County, PA LEPC and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She can be reached at 1-800-HOT-HOGS® (468-4647) or by email at [email protected]