OSHA’s final rule on 29 CFR 1910 Subpart D, “Walking-Working Surfaces,” is finally here. It’s 26 pages of nine-point font equaling 21,675 words, and I read them all. It’s big, and if you include the preamble in your analysis, it is also complicated. It was just as hard to write about as it was to read. I guess that shouldn’t be unexpected for a final rule that has been in the works since 1983. The original 1910 Subpart D was published in 1971. The first update was proposed in 1983, but it was never ratified. Proposals were again considered in either the Construction standard or the General Industry standard in 1990, 1994 and 2003. This edition of the final rule for 1910 Subpart D covers it all. OSHA should be congratulated for bringing almost all of the fall-related standards into one location, making it easier for the employer to find rules related to working surfaces under one subpart instead of having to search for those rules that may affect the employer’s workplace. This may be news to some novice safety professionals in the utility industry, but not all regulations affecting us are restricted to 1910.269 or 1926 Subpart V. Subpart D applies, so it is important to be familiar with it.
Preventing falls is almost the entire purpose of rules for walking-working surfaces. The surfaces are not always those spaces of aisles between walls. Most walking or working spaces in the workplace are not defined aisles; they are more likely to be incidental spaces about the work area. It is quite easy for those incidental spaces to be encumbered by tools, materials and process waste that create stumbling or tripping hazards. In addition, many of those working spaces are raised surfaces, from the tops of foundations to the tops of skyscrapers. That being the case, OSHA has brought into Subpart D the body of fall protection standards. You will now find a greatly expanded section on ladders; step bolts (towers) and manhole steps; scaffolds and rope descent systems (building maintenance); the duty to have fall protection; new and expanded requirements on fall protection equipment design; and some expanded language on the training of employees to recognize and prevent falls in the workplace.