OSHA’s Walking-Working Surfaces Deadline Arrived in May – Did You Prepare?

The Occupational Safety & Health Administration (OSHA) issued a final rule that took effect on January 17, 2017, updating its 44-year old general industry Walking-Working Surfaces standard. The revisions are significant, and include new technology and industry methods intended to reduce the number of fall-related employee injuries and deaths. OSHA estimates the final rule will prevent 29 fatalities and more than 5,800 injuries a year.

Who does the final rule cover?

The final rule applies to all general industry workplaces, including retail, (regardless of business size or number of employees) and covers all walking-working surfaces, which include horizontal and vertical surfaces such as:

  1. Floors
  2. Stairs
  3. Roofs
  4. Ladders
  5. Ramps
  6. Scaffolds
  7. Elevated walkway fall protection systems

What is the definition of “walking-working surfaces?”

Any surface on or through which an employee walks, works, or gains access to a work area or workplace location
(§ 1910.21(b)). Walking-working surfaces include:

  1. Floors
  2. Ladders
  3. Stairways
  4. Steps
  5. Roofs
  6. Ramps
  7. Runways
  8. Aisles
  9. Scaffolds
  10. Dockboards
  11. Step bolts

Walking-working surfaces include horizontal, vertical, and inclined or angled surfaces.

What are the major changes of the final rule?

The final rule includes multiple revisions to the existing general industry standards. These changes and new requirements, which have been in effect since January 17, 2017, include the following:

Inspection of walking-working surfaces (§1910.22(d))

Walking-working surfaces must be inspected “regularly and as needed” by the employer to ensure they are safe and well maintained. If hazardous conditions are identified, they must be immediately repaired or the hazard must be guarded to ensure workers do not use the area until it is repaired.

Updated Scaffolding Requirements (§1910.27(a))

The final rule replaces the outdated general industry scaffold standards with the requirement that employers comply with OSHA’s construction scaffold standards found in part 1926, Subpart L (Scaffolds).


Employers who have dockboards have been required to follow the requirements set forth in Standard 1910.26. Dockboards must now have a means to prevent equipment from running off the edge of the dockboard, unless it can be shown no such hazard exists. Portable dockboards must be capable of being anchored so that they cannot move out of a safe position.

Training (§1910.30)

Workers exposed to fall hazards must be trained to recognize fall hazards, minimize the hazards, and correctly use personal fall protection systems and equipment.

Training for the installation and maintenance of the overall personal fall protection system must include procedures for installation, inspection, operation, maintenance, and disassembly.

Workers must be trained on proper hook-up, anchoring, tie-off techniques, equipment inspection methods, and storage, as specified by the manufacturer, for using the personal fall protection system.

Fall Protection Flexibility (§1910.28(b))

The final rule allows employers to protect workers from falls by choosing from a range of accepted fall protection systems, including personal fall protection systems. It eliminates the existing mandate to use guardrails as the primary fall protection method and gives employers the flexibility to determine what method they believe will work best with their specific workplace situation. This approach has been successful in the construction industry since 1994. The final rule allows employers to use non-conventional fall protection practices in certain situations, such as designated areas on low-slope roofs for work that is temporary and infrequent, and fall protection plans on residential roofs when employers demonstrate guardrail, safety net, or personal fall protection systems are not feasible or create a greater hazard (§1910.28(b)(1) and (b)(13)).

Rope Descent Systems and Certification of Anchorages (§1910.27(b))

The final rule codifies OSHA’s memorandum for employers who use rope descent systems (RDSs) to perform elevated work. The final rule prohibits employers from RDSs at heights greater than 300 feet above grade, unless they demonstrate it is not feasible or creates a greater hazard to use any other system above that height. This rule will require building owners to affirm in writing, and employers to obtain, information where permanent building anchorages used for RDS have been inspected, tested, certified, and maintained as capable of supporting 5,000 pounds for each worker attached.

RDSs usually consist of a roof anchorage, support rope, descent device, carabiners or shackles, chair or seatboard. These systems are typically used throughout North America to perform elevated work, such as window washing.


Installation of personal fall arrest or ladder safety systems on new fixed ladders over 24 feet tall must be completed. Also by this date, employers must ensure existing fixed ladders over 24 feet in height, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system.

For portable ladders, the new revisions require employers to ensure the following:

  1. Rungs and steps are slip resistant.
  2. Portable ladders used on slippery surfaces are secured and stabilized.
  3. Portable ladders are not moved, shifted, or extended while a worker is on them.
  4. Top steps and caps of stepladders are not used as steps.
  5. Ladders are not fastened together to provide added length unless designed for such use.
  6. Ladders are not placed on boxes, barrels, or other unstable bases to obtain additional height.

Personal Fall Protection System Performance and Use Requirements (§1910.140)

The final rule, which allows employers to use personal fall protection systems (i.e., personal fall arrest, travel restraint, and positioning systems), adds requirements for the performance, inspection, use, and maintenance of these systems. As with OSHA’s construction standards, the final rule prohibits the use of body belts as part of a personal fall arrest system.

Phase-out of the “Qualified Climber” Exception in Outdoor Advertising (§1910.28(b)(10))

The final rule phases-out OSHA’s directive allowing qualified climbers in outdoor advertising to climb fixed ladders on billboards without fall protection and phases-in the requirement to equip fixed ladders (over 24 feet in height) with ladder safety or personal fall arrest systems. Outdoor advertising employers must follow the fall protection phase-in timeline for fixed ladders. However, if ladders do not have any fall protection, outdoor advertising employers have two years to comply with the existing standard (i.e., install a cage or well) or, instead, they may install a ladder safety or personal fall arrest system, both of which are cheaper than cages or wells.

Plan Ahead for November 18, 2036

Replacing Cages & Wells on Fixed Ladders

By November 18, 2036, cages and wells on general industry fixed ladders must be phased-out as the primary means of fall protection. Fixed ladders that currently feature a cage or well will have to be equipped with a ladder safety system or personal fall arrest system.

When do the requirements become effective?

Most of the new requirements were effective January 17, 2017. OSHA is giving employers additional time for some requirements, such as:

Final Subpart D Section and Requirement Compliance Date
§1910.30(a) and (b) – Deadline by which employers must train employees on fall and equipment hazards May 17, 2017
§1910.27(b)(1) – Certification of anchorages November 20, 2017
§1910.28(b)(9)(i)(A) – Deadline by which employers must equip existing fixed ladders with a cage, well, ladder safety system, or personal fall arrest system November 19, 2018
§1910.28(b)(9)(i)(B) – Deadline by which employers must begin equipping new fixed ladders with a ladder safety system or personal fall arrest system November 19, 2018
§1910.28(b)(9)(i)(D) – Deadline by which all fixed ladders must be equipped with a ladder safety system or personal fall arrest system November 18, 2036

Will states with OSHA-approved programs adopt the standards?

Yes. States with OSHA-approved state plans have six months to adopt standards that are at least as effective as Federal OSHA standards. Many state plans adoptstandards identical to OSHA, but some state plans may have different or more stringent requirements.

What is a state plan?
Visit OSHA State Plan for more information.

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