WRITTEN BY GARY SMITH, APARTMENT BUILDING MANAGEMENT WORKERS COMPENSATION SELF INSURED FUND
According to the U.S. Department of Labor, falls from heights and falls on the same level (i.e., a working surface) are among the leading causes of serious work-related injuries and deaths. As a result, OSHA issued a final ruling to update general industry (GI) walking-working surfaces and fall protection standards. The rule affects a wide range of workers, from painters to general laborers. It incorporates advances in technology, industry best practices, and national consensus standards to provide effective and cost-efficient worker protection.
MIOSHA has followed suit by adopting major changes to its GI requirements for walking-working surfaces and fall protection. These revisions follow OSHA’s updates in addressing slip, trip, and fall hazards (OSHA Subpart D, Walking-Working Surfaces) and requirements for personal fall protection systems (in OSHA Subpart I, Personal Protective Equipment).
The amended MIOSHA GI Part 2. Walking-Working Surfaces became effective on February 2, 2018, and some provisions have delayed compliance deadlines, which are listed below:
- Train workers on fall hazards. Before any employee is exposed to a fall hazard, the employer must provide training to each employee who uses personal fall protection systems or is required to be trained as specified elsewhere in Subpart D on or before June 4, 2018.
- Train workers on equipment hazards. The employer must train each employee in the proper care, inspection, storage, and use of equipment covered by Subpart D before an employee uses the equipment on or before June 4, 2018.
- Test and certify permanent anchorages for rope descent systems to ensure they can support 5,000 pounds for each employee attached on or before December 5, 2018.
- On existing fixed ladders that extend more than 24 feet above a lower level, install a personal fall arrest system, ladder safety system, cage, or well on or before November 19, 2018.
- On new fixed ladders that extend more than 24 feet above a lower level, install personal fall arrest system or ladder safety systems on or before November 19, 2018.
- On all fixed ladders that extend more than 24 feet above a lower level, replace cages and wells with ladder safety system or personal fall arrest systems on or before November 18, 2036.
Also, MIOSHA rescinded its fixed ladder (GI Part 3) and portable ladder (GI Part 4) because those ladder types are now both covered under the revised GI Part 2.
To assist in a good understanding of the effects of the Walking-Working Surfaces rule, MIOSHA has prepared a comparison document that is available online. The document has tables that name each prior rule that has been affected and identify what new rule or rules replaced it. The first column of each document contains the rescinded rule (struck through). The second column contains the corresponding, comparable new rule(s) that could be used to address the same hazard. In some cases, there may be more than one applicable rule in the new regulations.
Be sure to review MIOSHA GI Part 2. Walking-Working Surfaces and the comparison document to determine how the changes apply to your workplaces and what actions are necessary to take by each compliance deadline.
Should you require assistance with understanding or applying the new Walking-Working Surfaces rule, please contact Gary Smith, CRM, 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 General Industry Part 2 Comparison: http://www.michigan.gov/documents/lara/lara_miosha_GI_2_Comparison_Old_and_New_Rules_612865_7.pdf