OSHA's Walking-Working Surfaces Rule

Falls from elevated work platforms are a reality. Unfortunately, they happen. Material handling systems are getting bigger, the platforms are getting taller, and the speed of the operation is increasing. A fall-related incident will have a massive negative effect on a company. It will cost them significant money; the entire plant can be closed down while the matter is being investigated, and the negative publicity, the loss of income, and an injury or loss of a member of the team will do great damage to a company. But, the thing is, these areas can be secured.

Soon OSHA is expected to publish its final rule for Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) in General Industry (Subpart D and Subpart I). It’s taken OSHA decades to push this proposed rule through and has been updated and changed various times to reflect current practices in the industry, as well as make sure it aligns with other OSHA standards.

The proposed rule from OSHA aims to give companies more flexibility in the safety devices that they implement, as well as prevent injuries and fatalities from falls. Here’s a bit of language from the proposed rule:

“The existing OSHA general industry standards recognize the use of guardrails and physical barriers as the primary methods for employee protection against falls...OSHA believes that the proposed rules will give employers the necessary flexibility to decide which fall protection method or system works best for the work operation being performed, while ensuring employees receive a level of protection that is effective and necessary. OSHA believes that many of these slips, trips and falls can be prevented and has devoted many years to assembling and analyzing information aimed at the elimination and prevention of hazards that cause these incidents.”

Given that OSHA is allowing employers to determine what safety devices may work best in their operations, it is important to have everyone who works in the facility be able to discuss their own day-to-day concerns with people in management so these concerns can be addressed. Many times, the work that employees are doing is repetitive and tiring, so it is important that management takes the time to access all the steps in the operation and look to determine how they can make all these steps safer. It is always a good idea to consult with professionals in the industry to help determine what areas are unsafe and how to make them safe. The ProGMA group in the MHI is an excellent resource for safety in the warehouse.

In our opinion, the best solution, and the solution now recommended by ANSI standards is to have a barrier in place where employees are exposed to ledges at all times. This is best accomplished with a dual-gate system, which essentially creates a box, or controlled-access area, around the pallet drop location. This system will consist of a gate at the ledge and a second gate behind the pallet, and the gates are interconnected so when one gate is open, the opposite gate is closed so the area always remains safe.