regulatory update - walking- working surfaces & leading ... · osha is revising and updating...

1. All Rights Reserved.4 April 2019© 3M 3M Confidential.

OSHA Regulatory Update - Walking-Working Surfaces & Leading Edge Applications

Technical Service2019


Heidi Lopez-Hidalgo, PEApplication Engineer

3M Fall Protection

s

Regulatory UpdateWalking-Working Surfaces and Personal

Protective Equipment

(Fall Protection Systems)

OSHA’s Final Rule

5. All Rights Reserved.4 April 2019© 3M

3M Confidential.

WWSR review and update.

-Fixed ladders

-Fall protection snap hook design requirements

-Working on flat roofs

-Training requirements


29 CFR 1910 General Industry

On November 17, 2016, OSHA published its final rule on Walking and

Working Surfaces.

The 513 page copy from the Federal Register can be downloaded at:

https://www.federalregister.gov/documents/2016/11/18/2016-

24557/walking-working-surfaces-and-personal-protective-equipment-fall-

protection-systems

29 CFR 1910 General Industry Walking Working Surfaces Rule

https://www.federalregister.gov/documents/2016/11/18/2016-24557/walking-working-surfaces-and-personal-protective-equipment-fall-protection-systems


Who and what does the final rule cover?

The final rule applies to all general industry workplaces and covers all walking-working

surfaces, which include horizontal and vertical surfaces such as floors, stairs, roofs, ladders, ramps,

scaffolds and elevated walkways. The final rule also has provisions affecting fall protection

systems.

The final rule covers a wide variety of general industry entities, including building management

services, utilities, warehousing, retail, window cleaning, chimney sweeping and outdoor

advertising. It does not change construction or agricultural standards.

29 CFR 1910 General Industry WWSR


Summary:OSHA is revising and updating its general industry standards on walking-working surfaces to prevent and

reduce workplace slips, trips, and falls, as well as other injuries and fatalities associated with walking-

working surface hazards. The final rule includes revised and new provisions addressing, for example, fixed

ladders, rope descent systems, fall protection systems and criteria including personal fall protection

systems, and training on fall hazards and fall protection systems. In addition, the final rule adds

requirements on the design, performance, and use of personal fall protection systems.

The final rule increases consistency between the general industry and construction standards,

which will make compliance easier for employers who conduct operations in both industry sectors.

Similarly, the final rule updates requirements to reflect advances in technology and to make them

consistent with more recent OSHA standards and national consensus standards. OSHA has also

reorganized the requirements and incorporated plain language in order to make the final rule easier to

understand and follow. The final rule also uses performance-based language whenever possible to give

employers greater compliance flexibility. OSHA estimates that these changes will prevent 29 fatalities and

5,842 lost-workday injuries every year.



Effective Date:

This final rule became effective on January 17, 2017.

Some requirements in the final rule have compliance dates established after the effective date. This

allows time for employers to implement the standard.



Compliance Dates:

Most of the requirements in the final rule are existing provisions that OSHA is retaining and updating.

OSHA believes that employers are already in compliance with those provisions and, therefore, it is not

necessary to give additional time to comply with them. However, for some of the new requirements in the

final rule, OSHA is providing employers with additional time to come into compliance. The extended

compliance dates give employers time to get familiar with the new requirements, evaluate changes they

may need to make, purchase equipment necessary to comply with the final rule, and develop and present

required training. In addition, the extended compliance dates allows employers to upgrade their fall

protection systems as part of the normal ‘‘business cycle’’ or ‘‘useful life’’ of equipment (i.e., cage, well,

fixed ladder), which reduces compliance costs.



Compliance Dates:The following table specifies the amount of additional time OSHA is giving employers to certify

anchorages, equip fixed ladders with fall protection, and train workers:



This means as of 11/19/18 all ladders over 24’ must have protection and all new ladders over 24’ must have a ladder

safety system or personal fall arrest system.


SRL mounted at top of ladder

Fall Arrest System on

entire ladder


Standards with significant industry impact to product performance and certification.

ANSI/ASSE Z359.12-2009 - Connecting Components for Personal Fall Arrest System

When published in 2007, this standard implemented a significant increase to gate design strength used in

snap hooks and carabiners for personal fall arrest systems.

ANSI/ASSE Z359 Fall Protection Code

Before November 2007 Current

5000 pounds ultimate tensile strength 5000 pounds ultimate tensile strength

Gate Face 220 pounds Gate Face 3600 pounds

Gate Side 350 pounds Gate Side 3600 pounds

100% proof load at 3600 pounds 100% proof load at 3600 pounds


• Fall Protection Snap Hooks, D-Rings and Carabiners. The final rule requires that D-rings, snaphooks, and

carabiners be proof tested to a minimum tensile load of 3,600 pounds without cracking, breaking, or incurring

permanent deformation. OSHA also added a new requirement to final paragraph (c)(8) specifying that the gate

strength of snaphooks and carabiners also must be proof tested to 3,600 pounds in all directions. This direction

aligns with ANSI/ASSE Z359.12 standard for Connection Components for personal fall arrest systems.



Are your people working on flat roofs?


• Low-Slope Roof. This is a new term that OSHA added to the final rule. Low-slope roof is defined as a roof with

a slope less than or equal to a ratio of 4 in 12. A ratio of 4 in 12 means a vertical rise of 4 units (e.g., inches, feet,

and meters) to every 12 units of horizontal run. The final definition is almost identical to the definition of ‘‘low-

slope roof’’ found in the construction fall protection standard in § 1926.500(b). OSHA added this term to final

paragraph (b) because the final rule includes a new provision on controlling fall hazards on low-slope roofs (final

§ 1910.28(b)(13)), which is consistent with the construction fall protection standard in § 1926.501(b)(10). OSHA is

aware that low-slope roofs also are referred to as ‘‘flat roofs.’’ However, even a so-called ‘‘flat roof’’ has some

slope to allow for drainage. As such, OSHA believes that the term ‘‘low-slope roof’’ more accurately represents

these roofing configurations.

• Less than 6 feet from edge: acceptable forms of fall protection are guard rails, nets, travel restraint or PFAS.

• 6 feet to less than 15 feet from edge: acceptable forms of fall protection are guard rails, netting, travel restraint or

PFAS. Employer may use a designated area (warning line) when performing work that is both infrequent and temporary.

• 15 feet or more from edge: acceptable forms of fall protection are guard rails, netting, travel restraint or PFAS or

designated area (warning line). Employer is not required to provide any fall protection if work is both infrequent and

temporary, and they implement and enforce a work rule prohibiting employee from going within 15 feet of edge without

using fall protection.

29 CFR 1910 General Industry WWSRWhat is required regarding Fall Protection?


• Training (§1910.30).


http://www.google.com/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0ahUKEwj44pi-xb3RAhXQNFAKHRdLDJYQjRwIBw&url=http://www.usaswimming.org/DesktopDefault.aspx?TabId%3D1960&bvm=bv.144210762,d.ZWM&psig=AFQjCNFFaevkh8h4zX_a5p7hQNCPojxPYA&ust=1484342652439660


Training Requirements (§1910.30)(a) Fall Hazards. (1) Before any employee is exposed to a fall hazard, the employer must provide training for each

employee who uses personal fall protection systems or who is required to be trained as specified elsewhere in this subpart. Employers must ensure employees are trained in the requirements of this paragraph on or before May 17, 2017.

(2) The employer must ensure that each employee is trained by a qualified person.

(3) The employer must train each employee in at least the following topics:

(i) The nature of the fall hazards in the work area and how to recognize them;

(ii) The procedures to be followed to minimize those hazards;

(iii) The correct procedures for installing, inspecting, operating, maintaining, and disassembling the personal fall protection systems that the employee uses; and

(iv) The correct use of personal fall protection systems and equipment specified in paragraph (a)(1) of this section, including, but not limited to, proper hook up, anchoring, and tie-off techniques, and methods of equipment inspection and storage, as specified by the manufacturer.

(b) Equipment hazards. (1) The employer must train each employee on or before May 17, 2017 in the proper care, inspection, storage, and use of equipment covered by this subpart before an employee uses this equipment.

Additional requirements apply to those using dockboards and rope descent systems. The standard mirrors 1926 language

regarding Re-Training.


• Training – Key Points (§1910.30).• Deadline for Training is May 17, 2017

• 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.

• Trainer must be a qualified person and train workers to correctly:

• Identify and minimize fall hazards

• Use personal fall protection systems, safety nets, designated areas, dockboards, fixed, portable and mobile

ladders and rope descent systems

• Use, maintain, inspect and store equipment or systems used for fall protection

• Qualified Person Definition• Qualified describes a person who, by possession of a recognized degree, certificate, or professional standing, or who by

extensive knowledge, training, and experience has successfully demonstrated the ability to solve or resolve problems

relating to the subject matter, the work, or the project.

• Whenever there is a change in the workplace operations or equipment, or employer believes employee would

benefit from additional training based on lack of knowledge or skill, worker must be retrained.



Training requirement in a nutshell

Employers must ensure employees are trained by a qualified person on or before May 17, 2017.

Qualified describes a person who, by possession

of a recognized degree, certificate, or

professional standing, or who by extensive

knowledge, training, and experience has

successfully demonstrated the ability to solve or

resolve problems relating to the subject matter,

the work, or the project.


Residential RoofsWhy did OSHA add the residential roof provision to the final rule?

OSHA included this provision in the final rule to increase consistency between the general industry

and construction standards, which makes compliance easier for general industry employers who

perform both types of activities on residential roofs. Also, requiring employers to develop and

implement a fall protection plan ensures that employers take additional action to reduce fall

hazards when guardrail, safety net, and personal fall protection systems cannot be used. Many

stakeholders urged OSHA to add this provision to the final rule.

Rolling StockFinal Rule does not include any specific requirements for fall protection on rolling stock and motor

vehicles and OSHA’s current enforcement policies on rolling stock and motor vehicles will remain

in effect. This issue is discussed further in the Summary and Explanation for final rule § 1910.21(a).



•What is a Leading Edge (LE) as it relates to Fall Protection ?

•Leading Edge - unprotected border, perimeter or opening where a fall hazard exist.•Typical LE will force the lifeline/ lanyard to “bend” over the edge •Sharp Edge – many leading edges also present sharp edge hazards•Leading Edge / Sharp Edge - typically combined together


Leading Edge Fall Protection

• What are the unique risks of a leading edge and sharp edge?

• Increased fall distance because typical anchor point is at foot level

• Unpredictable lock up speed – self retracting device will only sense fall when user’s

D-ring moves past the leading edge

• Increased fall distance, which means the fall clearance requirement increases

• Increased arresting forces

• Potential for sharp edge to cut or severely damage lifeline

• Increased potential for swing falls


Leading Edge Fall Protection•What are the unique risks of a leading edge and sharp edge?

• Increased fall distance because typical anchor point is at foot

level










• Unpredictable lock up speed –

• Self retracting device will only sense fall when user’s D-ring moves past the leading edge







• What standards address the connecting

system for LE Fall protection?

• ANSI Z359.14 standard (US) • ANSI Z359.14 standard for SRL’s has specific test criteria,

• Testing simulates added free fall distance

• Testing performed over sharp steel edge (.005 inch radius)

• Testing for swing fall over steel edge as well as straight down



• ANSI Z359.14 standard for SRL’s has specific

test criteria.

• Testing simulates added free fall distance

• Testing performed over sharp steel

edge (.005 inch radius)

• Testing for swing fall over steel edge

as well as straight down

This Photo by Unknown Author is licensed under CC BY-SA

http://www.flickr.com/photos/capitalk/5585434498/

https://creativecommons.org/licenses/by-sa/3.0/



• What is the difference between “non-LE” and “LE” rated fall

protection equipment?

• Lifeline material typically larger, stronger, more cut resistant

• Non-LE fall protection equipment is typically rated for 6 ft. free fall and limited edge contact.

• Typically has external energy absorber

• SRL-LE can be used in non-LE applications.

• No added clearance is needed.

• Performance is similar



•What is the difference between “non-LE” and “LE” rated fall protection equipment?











• Non-LE fall protection equipment is typically rated for 6 ft. free fall

and limited edge contact.











•SRL-LE can be used in non-LE applications.






• LE equipment is rated / tested for longer free fall distances

• Increased energy absorbing ability. SRL with built in energy absorber at hook end


Why Leading Edge Matters

Non Leading Edge Web Based Lanyard

Link to Wed Based Lanyard Video

https://multimedia.3m.com/mws/media/1639792O/non-le-web-based-lanyard.mp4

https://multimedia.3m.com/mws/media/1639792O/non-le-web-based-lanyard.mp4



Non Leading Edge Cable Based SRL

Link to Cable Based Non-LE Video

https://multimedia.3m.com/mws/media/1639791O/non-le-cable-based-srl.mp4

https://multimedia.3m.com/mws/media/1639791O/non-le-cable-based-srl.mp4



Leading Edge Cable Based SRL

What is the Design Difference for Leading Edge?

Link to Cable Based LE Video

https://multimedia.3m.com/mws/media/1639795O/le-cable-based-srl.mp4

https://multimedia.3m.com/mws/media/1639795O/le-cable-based-srl.mp4



• ANSI only addresses steel edges.

• SRL-LE’s were tested for horizontal use and falls over a steel edge

without burrs.

• SRL-LE’s may be used in situations where a fall may occur over steel

edges, such as those found on steel shapes or metal sheeting.

• Avoid working where the lifeline will continuously or repeatedly abrade against sharp or

abrasive edges. Eliminate such contact or protect edges using a heavy pad or other means.

• Inspect the lifeline frequently for cuts, fraying.



• ANSI only addresses steel edges.

• SRL-LE’s were tested for horizontal use and falls over a steel edge without burrs.

• SRL-LE’s may be used in situations where a fall may occur over steel edges, such as those found on steel

shapes or metal sheeting.

• Avoid working where the lifeline will continuously or repeatedly

abrade against sharp or abrasive edges.

• Eliminate such contact or protect edges

using a heavy pad or other means.

• Inspect the lifeline frequently for

cuts, fraying.



• Using LE rated product on abrasive edges, such as concrete -

• Can be used on finished concrete with a rounded edge.

• End user’s Competent Person must be involved and have ownership of the set up!

• Discuss work application with manufacturer if needed

• Reference ANSI Z359 Committee Bulletin of May 2018

https://www.assp.org/docs/default-source/Standards-Documents/z359-bulletin-for-z359-14-testing.pdf?sfvrsn=4

https://www.assp.org/docs/default-source/Standards-Documents/z359-bulletin-for-z359-14-testing.pdf?sfvrsn=4



• Examples of LE rated products

• Symbol typically used on 3M LE rated products

• Tested for use in LE applications

• Foot level connection

• Sharp edge

Additional information on OSHA’s rule on walking-working surfaces and personal fall protection systems can be found at www.osha.gov/walking-working-surfaces and

https://www.osha.gov/walking-working-surfaces/faq.html or 3M whitepaper at http://api.capitalsafety.com/api/assets/download/1/48037554

Thank [email protected]

(651)-285-7081

http://www.osha.gov/walking-working-surfaces

https://www.osha.gov/walking-working-surfaces/faq.html

http://api.capitalsafety.com/api/assets/download/1/48037554

mailto:[email protected]

http://www.3m.com/FallProtection