Health and Safety Resource

​October-November 2017


Heads up: New walking-working surfaces rules for general industry take effect Nov. 1

Oregon OSHA’s entire set of general industry rules for walking-working surfaces will be changing next month.

The new rules – there are 18, not including historical notes, a table of figures and a table of tables – are in Division 2, Subdivision D, of Oregon OSHA’s occupational safety and health rules.

Many of the rules – which are intended to prevent slips, trips, falls, and protection from falling objects – are identical to those that federal OSHA adopted in Nov. 2016; Oregon OSHA did not adopt all of OSHA’s rules, however, and created a number of Oregon-initiated rules to replace them.​

For many employers in general industry, two of the most significant new requirements cover rope descent and rope access systems –Oregon-initiated rule is 437-002-2027 – and the minimum height of guardrails; specifically, guardrails with a top edge height less than 39 inches will be out of compliance on Nov. 1, 2017.

Although the rules become effective Nov. 1, some have delayed effective dates – ranging from two months to 18 years – which are intended to give employers time to comply with the requirements. You might also want to note that Oregon OSHA’s delayed effective dates are different than those set by federal OSHA. But don’t worry. Read on to learn more about the new walking-working surfaces rules.​

Important definitions (1910.21 and 437-002-2021)

Walking-wor​king surface
Any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area.
Rope descent system
A suspension system that allows an employee to descend in a controlled manner and stop at any point during the descent. A rope descent system usually consists of a roof anchorage, support rope, a descent device, carabiners or shackles, and a chair or seatboard.
Low-slope roof
A roof that has a slope less than or equal to a ratio of 2 in 12 (vertical to horizontal)

General requirements (1910.22 and 437-002-0022)

  • Workplaces, including passageways, storerooms, service rooms, and other walking-working surfaces, must be clean, orderly, and sanitary.
  • Employees must have a safe way to access and exit all walking-working surfaces.
  • Walking-working surfaces must be inspected regularly and kept safe.
  • Three new Oregon-initiated rules include additional Oregon general requirements, ramps and runways for vehicles, and piers and wharves.

Ladders (1910.23 and 437-002-0026)

Ladders covered include portable ladders, job-made ladders, fixed ladders, mobile ladder stands, and mobile ladder stand platforms. Not included are ladders used in emergencies (such as firefighting, rescue, and law enforcement activities) and ladders that are an integral part of machines or equipment.

A new Oregon-initiated rule applies to the selection and use of portable ladders, including job-made ladders, in addition to the requirements in Ladders, 1910.23.

Step bolts and manhole steps (1910.24)

A step bolt is a bolt or rung attached at intervals along a structural member used for climbing or standing and as a handhold when climbing or standing.

Step bolts installed before Jan. 1, 2018, must be capable of supporting their maximum intended loads.

Step bolts installed on or after Jan. 1, 2018:

  • Must be constructed of or coated with corrosion-resistant material if they are in areas where corrosion may occur.
  • Must be capable of supporting at least four times their maximum intended loads.

Manhole steps are steps that are individually attached to, or set into, the wall of a manhole. Manhole steps must be inspected at the start of each work shift.

Manhole steps installed on or after Jan. 1, 2018, must meet specific requirements for slip resistance, corrosion resistance, width, and vertical spacing.

Stairways (1910.25)

A stairway consists of risers and treads that connect one level with another, including the landings and platforms in between those levels. The term “stairs” and “stairway” are interchangeable. All stairways are covered by the requirements, except stairs on floating roof tanks and scaffolds, stairs designed into machines, and stairs on self-propelled motorized equipment.

Stairways must be fixed or permanently installed at an angle between 30 and 50 degrees from horizontal unless an employer can demonstrate that they are not feasible; then, spiral, ship, or alternating tread-type stairs are acceptable alternatives.

Stairways built on or after Jan. 1, 2018, must have a maximum riser height of 9.5 inches and a minimum tread depth of 9.5 inches.

When a door or a gate opens directly onto a stairway, a platform must be available and the swing of the door or gate must not reduce the platform’s usable depth less than:

  • 20 inches for platforms installed before Jan. 1, 2018.
  • 22 inches for platforms installed on or after Jan. 1, 2018.

Dockboards (1910.26)

A dockboard is a device that spans a gap or compensates for the difference in elevation between a loading platform and a transport vehicle. Dockboards include bridge plates, dock plates, and dock levelers.

Dockboards must be able to support their maximum intended loads.

Dockboards used on or after Jan. 1, 2018, must prevent vehicles from running off the edge.

Scaffolds and rope descent systems (1910.27)

Scaffolds must meet all of the construction industry requirements for scaffolds. (You’ll find the requirements in Division 3, Subdivision L). Those who erect, dismantle, move, or work from a scaffold must be also trained according to the requirements in 1926.454, Training requirements.

Rope descent and rope access systems (437-002-2027)

This new Oregon initiated rule establishes safety requirements for rope descent and rope access systems, which are used for tasks such as cleaning buildings, inspecting dams and bridges, and reaching difficult areas.

A rope descent system is a suspension system that allows a worker to descend in a controlled manner and stop at any point during the descent. A rope descent system usually consists of a roof anchorage, support rope, a descent device, carabiners or shackles, and a chair or seatboard.

A rope access system uses two ropes to reach a work area; one rope serves as the primary means of support and the second rope is used to stop a fall.

By Dec. 1, 2018:

  • The building owner must inform the employer in writing that each permanent anchorage has been identified, tested, certified, and maintained so it can support at least 5,000 pounds.
  • Employees must not use any permanent anchorage before the employer has obtained the written information from the building owner.

Duty to have fall protection and falling object protection (1910.28)

This rule requires employers to protect employees who are exposed to falls – generally four feet or more above a lower level – and falling objects. The rule identifies 15 walking-working surfaces where falls are possible. The table below summarizes the hazards and shows the options for protecting workers (which are covered in the subsequent walking-working surfaces rule: Fall protection systems and falling object protection, 1910.29).


​Walking-working surfaces hazards and fall-protection options
​Walking-working surface hazards (from 1910.28​) Fall protection options (from 1910.29, Fall protection systems - criteria and practices)
​Guard rail Safety net Designated area​ Cover ​Handrail, stair rail ​Cages, wells, platforms ​Ladder safety system ​Personal fall protection system*
​Unprotected sides and edges ​X ​X ​  ​  ​  ​  ​  ​X
​Hoist areas ​X ​  ​  ​  ​  ​  ​  ​X
​Holes ​X ​  ​  ​X ​  ​  ​  ​X
​Dockboards ​X ​  ​  ​  ​X ​  ​  ​ 
​Runways ​X ​  ​  ​  ​  ​  ​  ​ 
​Dangerous equipment ​X ​X ​  ​  ​  ​  ​  ​X
​Openings ​X ​X ​  ​  ​  ​  ​  ​X
​Fixed ladders** before 11/1/19 ​  ​  ​  ​  ​  ​X ​X ​X
​Fixed ladders** on or after 11/1/19 ​  ​  ​  ​  ​  ​  ​X ​X
​Billboards*** before 11/1/19 ​  ​  ​  ​  ​  ​X ​X ​X
​Billboards on or after 11/1/19 ​  ​  ​  ​  ​  ​  ​X ​X
​Stairways ​X ​  ​  ​  ​X ​  ​  ​ 
​Rope descent systems ​  ​  ​  ​  ​  ​  ​  ​X
​Low-slope roofs ​X ​X ​X ​  ​  ​  ​  ​X
​Slaughtering facility platforms ​X ​  ​  ​  ​  ​  ​  ​X

*Personal fall protection systems must meet the requirements in 1910.140, (Division 2, Subdivision I, Personal protective equipment).
**Applies to fixed ladders more than 24 feet above a lower level
***Other requirements apply when an employee climbs a fixed ladder before Nov. 1, 2019, that is not equipped with a cage, well, personal fall arrest system, or a ladder safety system.

The requirements in this rule do not apply to:

  • Portable ladders
  • Workers inspecting conditions at the start of a shift or after all work has been completed (workers must use fall protection if it is available).
  • Exposed perimeters of stages and rail-station platforms.
  • Powered platforms
  • Aerial lifts
  • Telecommunications work
  • Electrical power generation, transmission, and distribution work

Fall protection systems and falling object protection – criteria and practices (1910.29)

This rule sets the requirements for the fall protection systems and protection from falling objects that employers can use to protect their employees. Those include:

  • Guardrail systems
  • Safety net systems
  • Designated areas
  • Covers for holes
  • Handrail and stair rail systems
  • Cages, wells, and platforms used with fixed ladders
  • Ladders used for outdoor advertising billboards
  • Ladder safety systems
  • Personal fall protection systems
  • Protection from falling objects (including toeboards and canopies)
  • Grab handles
Remember that guardrail systems, handrail systems, and stair rail systems serve different purposes.
  • A guardrail is a barrier erected along an unprotected or exposed side, edge, or other area of a walking-working surface to prevent employees from falling to a lower level. Regardless of its installation date, the top edge height of a guardrail must be 42 inches, plus or minus three inches high. Guardrails with a top edge height less than 39 inches will be out of compliance on Nov. 1, 2017.
  • A handrail is a rail used to provide employees with a handhold for support.
  • A stair rail or stair rail system is a barrier erected along the exposed or open side of stairways to prevent employees from falling to a lower level.

The height of stair rail systems installed before Jan. 1, 2018, must not be less than 30 inches from the leading edge of the stair tread to the top surface of the top rail.

The height of stair rail systems installed on or after Jan. 1, 2018, must not be less than 42 inches from the leading edge of the stair tread to the top surface of the top rail.

What are designated areas?

A designated area is a distinct portion of a walking-working surface delineated by a warning line; employees may work without additional fall protection in a designated area when they are on a low-slope roof – a roof that has a slope less than or equal to a ratio of 2 in 12 (vertical to horizontal). The warning line – a rope, wire, tape, or chain – warns the employees that they are approaching an unprotected side or edge.

Training requirements (1910.30)

Training in a language the employee understands is required for employees who use a personal fall protection system and any other equipment covered by the walking-working surfaces rules. Training must cover the manufacturer’s instructions and proper care, storage, and use of the equipment.

Employees who use personal fall protection systems must be trained by a qualified person on or before May 17, 2018.

Have questions about the new walking-working surfaces rules?

Send Ken Langley in Oregon OSHA’s Technical Section and email: ken.e.langley@oregon.gov


Walking-working surfaces requirements that have delayed effective dates

Before Jan. 1, 2018

Step bolts
Each step bolt installed before Jan. 1, 2018, must be capable of supporting its maximum intended load. 1910.24(a)(6)
Stairways
When a door or a gate opens directly on a stairway, a platform must be available and the swing of the door or gate must not reduce the platform’s usable depth to less than 20 inches for platforms installed before Jan. 1, 2018. 1910.25(b)(5)(i)
Stairways
The requirements of paragraphs 1910.25(c)(2) and 1910.25 (3) do not apply to a fixed or permanent stairway installed before Jan. 1, 2018. Those stairways are in compliance if they meet the dimensions in Table D–1, Stairway Rise and Tread Dimensions, or they are installed at angles between 30 to 50 degrees from the horizontal. 1910.25(c)(5)
Stair rail systems
The height of stair rail systems installed before Jan. 1, 2018, must not be less than 30 inches from the leading edge of the stair tread to the top surface of the top rail. 1910.29(f)(1)(ii)(A)

On or after Jan. 1, 2018​

Step bolts
Each step bolt installed on or after Jan. 1, 2018, in an environment where corrosion may occur must be constructed of, or coated with, material that protects against corrosion. 1910.24(a)(1)
Step bolts
Each step bolt installed on or after Jan. 1, 2018, must be capable of supporting at least four times its maximum intended load. 1910.24(a)(7)
Manhole steps
Each manhole step installed on or after Jan. 1, 2018, must meet specific requirements for slip resistance, corrosion resistance, width, and vertical spacing. 1910.24(b)(2)
Stairways
When a door or a gate opens directly on a stairway, a platform must be available and the swing of the door or gate must not reduce the platform’s usable depth less than 22 inches. 1910.25(b)(5)(ii)
Dockboards
Dockboards put into initial service on or after Jan. 1, 2018, must be designed, constructed, and maintained to prevent transfer vehicles from running off the dockboard edge. 1910.26(b)(1)
Stair rail systems
The height of stair rail systems installed on or after Jan. 1, 2018, must not be less than 42 inches from the leading edge of the stair tread to the top surface of the top rail. 1910.29(f)(1)(ii)(B)

Before May 1, 2018

Training
Employers must provide training for each employee who uses a personal fall protection system. 1910.30(a)(1)
Training
Employers must train employees in the proper care, inspection, storage, and use of their equipment before they use it. 1910.30(b)(1)

Before Nov. 1, 2019

Fixed ladders
Each fixed ladder (that extends more than 24 feet above a lower level) installed before Nov. 1, 2019, must be equipped with a personal fall arrest system, ladder safety system, cage, or well. 1910.28(b)(9)(i)(A)
Outdoor advertising
When an employee engaged in outdoor advertising climbs a fixed ladder before Nov. 1, 2019, that is not equipped with a cage, well, personal fall arrest system, or a ladder safety system the employer must ensure the employee is trained, wears a body harness, keeps hands on the ladder, and is protected by a personal fall arrest system upon reaching the work position. 1910.28(b)(10)(ii)

On and after Nov. 1, 2019

Fixed ladders
Each fixed ladder (that extends more than 24 feet above a lower level) installed on and after Nov. 1, 2019, must be equipped with a personal fall arrest system or a ladder safety system. 1910.28(b)(9)(i)(B)

On and after Dec. 1, 2036

Fixed ladders
On and after Dec. 1, 2036, all fixed ladders (that extends more than 24 feet above a lower level) must be equipped with a personal fall arrest system or a ladder safety system. 1910.28(b)(9)(i)(D)

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