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OSHA 1910 Updates: Don’t Trip Up!

Posted by Christine Gunsaullus on Tuesday, November 14, 2017

Earlier this year, while writing specifications for a storage tank rehabilitation, I pulled up OSHA Section 29 CFR Part 1910.23 online and stared in disbelief. This standard used to provide design guidelines for handrails, but instead, I was reading about ladders. Plus many dimensions were different from what I remembered. Holy Cow! Had I been designing tank accessories wrong? How long had I been referencing these standards incorrectly? Had I finally lost my marbles?

I immediately reached out to all of my "tankie" friends, who design, build, and inspect storage tanks, but nobody was aware of these changes. Poking around on the Internet, I learned that changes to OSHA 1910 had only taken effect the day before, on January 17, 2017, so I felt a huge sense of relief. But while I wouldn’t expect ads from OSHA to pop-up on Facebook, I still thought somebody would have told me. So if nobody told me, you might be in the dark too, so I put together this quick summary to help you understand some of the new changes.

The Occupational Safety and Health Act (OSHA) was enacted in 1970 to assure safe and healthful working conditions. Since that time, the rate of workplace deaths per year was cut by 2/3 from 10 per 100,000 workers to just over three.

Slips, trips and falls are the cause of more than a third of workplace injuries and deaths every year, and Part 1910 works to counteract this. These changes have been in the works for more than 25 years, but any new rules must show a cost-benefit to businesses. OSHA estimates that these changes will prevent 29 worker deaths and 5,842 lost-workday injuries each year, with a net savings of $309.5 million per year by eliminating injuries and deaths.

FAQs about the new rules:

What changed?
OSHA explains: “The final rule revises and updates the requirements in the general industry Walking-Working Surfaces standards (29 CFR part 1910, subpart D), including requirements for ladders, stairs, dockboards, and fall and falling object protection; and it adds new requirements on the design, performance, and use of personal fall protection systems (29 CFR part 1910, subpart I).”

Specifically, the walking-working surfaces in general industry workplaces are defined as “any surface on or through which an employee walks, works, or gains access to a work area or workplace location… include floors, ladders, stairways, steps, roofs, ramps, runways, aisles, scaffolds, dockboards, and step bolts.” The rule incorporates advances in technology, industry best practices, and national consensus standards to provide effective and cost-efficient worker protection.

What Subparts of OSHA 1910 were revised?
A. Subpart D – Walking-Working Surfaces

Section	Previous Subpart D	New Subpart D
§1910.21	Definitions	Scope and definitions
§1910.22	General requirements	General requirements
§1910.23	Guarding floor and wall openings and holes	Ladders
§1910.24	Fixed industrial stairs	Step bolts and manhole steps
§1910.25	Portable wood ladders	Stairways
§1910.26	Portable metal ladders	Dockboards
§1910.27	Fixed ladders	Scaffolds and rope descent systems
§1910.28	Safety requirements for scaffolding	Duty to have fall protection and falling object protection
§1910.29	Manually propelled mobile ladder stands and scaffolds	Fall protection systems and falling object protection – criteria and practices
§1910.30	Other working surfaces	Training requirements

B. Subpart I – Personal Protective Equipment:

Addition of 1910.140 Personal Fall Protection Systems
Addition of 1910 Subpart I App C – Non-Mandatory Guidelines for Personal Fall Protection Systems
Addition of 1910 Subpart I App D – Non-Mandatory Guidelines for Test Methods and Procedures for Personal Fall Protection Systems

What are some examples of changes?
Here’s the good news: The new rules use common sense. Really! In the past, it infuriated me to have to replace or modify 41" high handrails atop a tank that met all of the other OSHA structural requirements, but were not 42" per the standard. There is now flexibility for handrails, and as long as they can withstand the required loads, the height can be 42" +/-3".

Employers have additional flexibility to achieve compliance, and the new standard aligns requirements for general industry with construction standards. Ladder safety system rules have been updated in regards to what is permitted, needed, and how the role of cages on fixed ladders will change. There are also requirements in regards to training and inspection, some of which have compliance deadlines in 2017 and 2018.

see a few tank photos & implications
Who must follow the rules of OSHA 1910?
All private sector general industry workers and workplaces, unless prohibited or pre-empted by another authority. So these rules do not apply to state or local governments, unless they are one of the 20 states with a safety program subject to the Federal OSHA rules.

Here in Pennsylvania, where our six offices are located, our public sector clients must follow the regulations of the PA General Safety Law No. 174, Title 34 of the PA Code, Section 6.1 – 47.398. But a quick review one General Safety Section, A-174: 21 for ladders, found general language calling for “safe” work areas and outdated construction safeguards like “safety belts.” Since I haven’t used a safety belt since 1994 when industry switched to safety harnesses, I believe the public sector could benefit from following the guidelines OSHA 1910 provides.

So far, I’ve only talked to one person who’s aware of these changes: my coworker, Architect Matt Clayton, AIA. While these changes may not affect you directly, they may affect your building or facility or some employees.

Contact us if you have questions about how changes to OSHA 1910 affect you or your workplace or post them below in the comments!

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