WRITTEN BY GARY SMITH, APARTMENT BUILDING MANAGEMENT WORKERS COMPENSATION SELF INSURED FUND
NOTE: In May we ran Part I, focusing on compliance deadlines. Part II outlines the content of the rule and how it is likely to apply to members.
The State of Michigan adopted the new federal OSHA standard pertaining to walking-working surfaces earlier this year. MIOSHA’s Part 2. Walking-Working Surfaces applies to all general industry workplaces in the State.
Let’s consider why this change occurred and some of the key requirements that may likely apply to your workplace.
Why the New Rules?
Slips, trips and falls are a leading cause of fatality and injury in general industry, which applies across numerous industries. The Bureau of Labor Statistics reports that slips, trips and falls account for 15 percent of all accidental deaths. Causing more fatalities than any other cause, second only to motor vehicle accidents. OSHA estimates that the new rules may prevent 29 fatalities and as many as 5,842 injuries annually, nationwide. The potential benefit is estimated to be up to $309.5 million dollars per year.
How Does it Apply?
The new standard, MIOSHA General Industry Part 2, presents both general and specific type requirements. The requirements are too numerous to mention them all here and they deserve your thorough review. Here are some of the more important:
Housekeeping – Employers must ensure that all places of employment, passageways, storerooms, service rooms, and walking-working surfaces are kept in a clean, orderly, and sanitary condition. Floors should be kept in a dry condition to the extent feasible or drainage must be maintained. Surfaces should also be free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow and ice.
Inspection, Maintenance, and Repair – Walking-working surfaces must be inspected regularly and as necessary and maintained in a safe condition. Hazardous conditions are to be corrected / repaired before being used again. If the correction or repair will be delayed, then the hazard must be guarded until conditions are addressed.
Ladders – Prior to each initial use in each work shift, ladders must be inspected for any damage or defects. Any ladder found to be damaged or defected must be immediately tagged as Dangerous – Do Not Use and removed from service until repaired or replaced.
Stairways – Stairs shall have uniform riser heights and tread depths between landings. They shall support at least five times the normal anticipated live load, but never less than the concentrated 1,000 pounds applied at any point.
Fall and Falling Object Protection – Employees exposed to unprotected sides of walking-working surfaces 4 feet or greater are protected by a guardrail system, safety net system, personal fall arrest system (PFAS), travel restraint or positioning system. Each hole (including skylights) that is 4 feet or more above a lower level shall be protected by covers, guardrail systems, travel restraint systems, and personal fall arrest systems. To protect employees from falling objects, toeboards, screens, or guardrail systems shall be used.
Low-Slope Roofs
- • Roofs less than or equal to a ratio of 4 in 12 (vertical to horizontal) have a few allowances depending upon the proximity of the work to the edge.
- • Less than 6 feet from the edge – the employer must ensure the employee is protected from falling by a guardrail system, safety net system, travel restraint system, or PFAS.
- • Between 6 feet and 15 feet from the edge – the employer must ensure each employee is protected from falling by using a guardrail system, safety net system, travel restraint system, or personal fall arrest system. The employer may use a designated area when performing work that is both infrequent and temporary. Both infrequent and temporary directly apply to employees performing up to monthly roof top inspections, air filter changes and HVAC equipment cleaning.
- • At or beyond 15 feet from the edge – the employer, if the work is both infrequent and temporary, is not required to provide any fall protection. But, they must implement and enforce a work rule prohibiting employees from going within 15 feet of the roof edge without using fall protection.
Employee Training – Employers must provide training on the nature of falls and how to recognize them; procedures to protect from falls; procedures for installing, inspecting, operating, maintaining, and disassembling fall protection systems; and the correct inspection/use/storage of personal fall arrest systems. Retraining is required to maintain skills and if there are changes in the workplace.
Should you require assistance with interpreting and applying the new walking-working surfaces standard in your workplace, please contact Gary L. Smith, CRM, CSRM, MLIR, Director of Risk Control at (517) 338-3367 or gary.smith@yorkrsg.com.
Resources:
- MIOSHA General Industry Part 2. Walking-Working Surfaces: http://www.michigan.gov/documents/CIS_WSH_part2_35455_7.pdf
- MIOSHA Comparison to Previous Standard: http://www.michigan.gov/documents/lara/lara_miosha_GI_2_Comparison_Old_and_New_Rules_612865_7.pdf
- OSHA Resources for Walking-Working Surfaces: https://www.osha.gov/walking-working-surfaces/index.html
- American Ladder Institute’s FREE Ladder Safety Training: https://laddersafetytraining.org/