Tag: Risk Management

OSHA’s Walking-Working Surfaces Standard and Fall Prevention

At the end of May, the Occupational Safety and Health Administration (OSHA) proposed updates to its stair rail system requirements related to walking-working surfaces and protective equipment.

As is often the case with new safety standards, many employers have asked for clarification. At Cornerstone Insurance Group, we want you to have peace of mind about your risk management strategies. Here is what you need to know about the latest in walking-working surfaces and general fall prevention standards.

What is New in the Walking-Working Surfaces Standard?

The biggest change in the Walking-Working Surfaces requirements is related to new handrails and stair rail systems with a width of less than 44 inches (found in Table D of this standard). The previous stair rail provision was unclear, stating:

“One stair rail system each open side”

But OSHA intended it to say:

“One stair rail system with handrail on each open side”

They hope that the new language clarifies any confusion in this particular safety standard. In addition, OSHA has eased restrictions on previously installed stair rail systems by allowing the top rail of those systems to act as a handrail if it’s as low as 30 inches.

What Do I Do if I’ve Abided by the Old Wording?

OSHA does recognize that many employers may have implemented stair rail safety standards that follow the previous language (i.e. stair width that’s less than 44 inches and open on both sides). 

However, there’s no need to worry. You do not have to modify your stair rail system if it was installed before the effective date of the new final rule as long as it was in compliance with OSHA standards at the time of installation.

OSHA now has two separate provisions for stairs with two open sides and a width of less than 44 inches. Flights of stairs that have two open sides, are less than 44 inches and installed before the effective date of a final rule would be required to have a stair rail system on each open side but do not need to have a handrail. 

Are There Other Revised Standards I Should Know About?

OSHA is also proposing provisions to Section 1910.29 called “Fall Protection Systems and Falling Object Protection-Criteria and Practices.” Many have expressed confusion over whether or not the top rail of a stair rail system can also serve as a handrail. 

The new proposed standard states that the top rail of stair rail systems installed prior to January 17, 2017 (the date of the final rule) can serve as a handrail if the top rail is 30 to 38 inches tall and meets OSHA’s other handrail requirements. Employers are not required to modify their stair rail systems if they complied with the previous ruling.

Cornerstone’s Risk Management team wants to ensure your workplace is as protected as possible from falls and other injuries. If you’re looking for a specialist to walk you through OSHA’s standards or want to create a risk management plan that works for you, contact Cornerstone today.

Top Cited OSHA Violations

The Occupational Safety and Health Administration (OSHA) releases a list each year of the most frequently cited violations. Knowledge of these violations can assist you in identifying and correcting similar risks in your company.

In November 2015, Congress enacted legislation requiring federal agencies to adjust their civil penalties to account for inflation. OSHA citation fees increased seven-fold in 2016 and will continue to go up with annual inflationary adjustments. The increase from 2019 to 2020 was 1.8%.

If you assess your safety program with an emphasis on correcting these commonly cited hazards, and you will be safer and save money in penalty fees!

Here are a few tips for mitigating some of the most frequently cited hazards associated with 3 of OSHA’s Top 10 citations. For the complete list, please watch my webinar presentation.

Fall Protection

Falls continue to be the leading cause of death in the construction industry accounting for over 33% of fatalities. Almost two-thirds of fall accidents are from roofs, ladders, and scaffolds.

The construction industry is a unique place to work, with job site conditions changing from day-to-day or even hour-to-hour. Fall exposures are frequent and varied. This safety challenge can be met with success if we pay attention to OSHA’s requirements under the “Fall Protection Standard (1926 Subpart M)”, “Scaffolds (1926 Subpart L),” and “Stairways and Ladders (1926 Subpart X)”.

Additional information and resources for Fall Protection can be found here:

https://www.osha.gov/SLTC/fallprotection/

Eye and Face Protection

Conduct a hazard assessment and identify those work tasks that require eye and face protection to guard employees from hazards like flying particles, chemicals, or optical radiation. Your assessment must include evaluation of exposures to both the employee performing the task or job, as well as other employees that might be working in the same area. These assessments will help you choose the correct eye and/or face protection to help prevent eye and face injuries. Keep in mind, normal prescription eyewear does not provide protection from impact or penetration hazards. To provide appropriate protection, prescription eyewear must be manufactured per the requirements of the “American National Standards Institute, ANSI Z87.1”. Otherwise, you could provide “wear-over” type eye protection.

Eye and face protection requirements are addressed in OSHA’s Construction Industry under the “Personal Protective and Lifesaving Equipment Standard, 1926 Subpart E“.

Hazard Communication

The Hazard Communication Standard (HCS) helps employers classify and identify chemical hazards and controls for safe use. It’s basically chemical safety in the workplace. Employers need to ensure that their employees understand the hazards presented by the chemicals they’re using, AND most importantly, what measures must be taken to prevent injury while using these chemicals.

Safety Data Sheets (SDS) for each chemical must be readily available to all employees and updated as needed. SDS contain important information from the manufacturer regarding the chemical hazards and safeguards.

Watch for improperly labeled or unlabeled containers. Accurate and compliant labeling will contain the following information:

  • The product identifier, i.e. the name of the chemical
  • The manufacturers’ name and address
  • A “Signal Word” to quickly ascertain the level of hazard, either “Danger” or “Warning.”
  • A “Hazard Statement” that describes the nature of the hazard(s), e.g. “causes serious eye damage”
  • A “Precautionary Statement(s)”, e.g. “wear appropriate eye protection”
  • And a “Hazard Information” pictogram(s)

Here is a great resource for employers to ensure compliance with “OSHA’s Hazard Communication Standard.”

Hazard identification and control are key components of a successful safety program.  Taking a closer look at OSHA’ s annual list of their Top 10 Most Frequently Cited Violations and appropriate measures to avoid them will help you in your ongoing safety efforts.  For more information please click the links below to watch the webinar or download the slide presentation.

OSHA’s Top Ten Cited Violations of 2019 – Webinar

Webinar Slide Presentation