Frank Marino, CSP •

Final Rule of OSHA’s Walking-Working Surface Standard for General Industry

Falls from heights and on the same level (a working surface) are among the leading causes of serious work-related injuries and deaths. OSHA has issued a final rule on Walking-Working Surfaces and Personal Fall Protection Systems to better protect workers in general industry from these hazards by updating and clarifying standards and adding training and inspection requirements (OSHA, 2016). The rule affects a wide range of workers, from painters to warehouse workers. It does not change construction or agricultural standards. You may be asking yourself what this has to do with fall protection in the construction industry? The answer may surprise you.

According to the OSHA Website, the final rule has aligned fall protection requirements for general industry with those for construction, easing compliance for employers who perform both types of activities. A good example would be skylight protection. How often have you seen skylights that have a sticker that says “meets OSHA requirements”? They are certainly becoming more abundant. But what exactly does “meets OSHA requirements” even mean? What OSHA requirements are they referring to? In most instances, those skylights met OSHA compliance with the General Industry standard, not the Construction standard that is applicable for construction operations. Essentially, OSHA was saying the skylights were safe for an employees of the building coming up to change filters on a HVAC unit, but not safe for a construction worker. This has led to significant confusion on many jobsites and potentially put construction contractors in violation. The new Walking-Working Surface should eliminate this confusion and should result in a safer work place for all employees. However, it may also come as a surprise to building owners who have spent money on “OSHA compliant” skylights that now find themselves in violation of updated OSHA compliance.

In other aspects, this new rule may not be as helpful for construction contractors. Has your company ever utilized the height / width calculation for parapet walls to be used for fall protection? If a parapet wall is a minimum of 30” high, and the height plus the width of the wall is a least 48”, then it was determined that the fall hazard was removed and this was a compliant method to protect construction employees. But what many don’t know is that this calculation was taken from a recommendation that was proposed at the beginning of the rulemaking process (originally proposed in 1990) for the Walking-Working Surface rule in the General Industry standard. Many companies then applied it to construction activities and was widely accepted by OSHA locally. The Final Rule for Walking-Working Surfaces for General Industry DID NOT adopt this calculation from the existing recommendation. What that means is OSHA may no longer consider this acceptable on a construction jobsite. In addition, OSHA also is rescinding all previous interpretations/directives that allowed classification of 'de minimis' for guardrails a couple inches short of 39 inches. The overall effect of these changes on the Construction Industry is yet to be seen OSHA goes on to say the rule incorporates advances in technology, industry best practices, and national consensus standards to provide effective and cost-efficient worker protection. Specifically, it updates general industry standards addressing slip, trip, and fall hazards (subpart D), and adds requirements for personal fall protection systems (subpart I). OSHA estimates that these changes will prevent 29 fatalities and 5,842 lost-workday injuries every year (OSHA, 2016).

If you have any questions or concerns regarding these changes, please contact the Safety Check office or visit

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