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OSHA’s New Walking-Working Surfaces Standard Imposes Significant New Requirements on Employers

Insight & Impact - Labor & Employment Regulatory Newsletter Fred Gants

ISSUE: OSHA’s New Walking-Working Surfaces Standard Imposes Significant New Requirements on Employers

In short, the updated Walking-Working Surfaces standard requires General Industry employers to “ensure that each employee on a walking-working surface with an unprotected side of edge that is 4 feet … or more above a lower level is protected from falling by:” a (a) guardrail system; (b) safety net system; or (c) personal fall protection system. See 29 CFR 1910.28(b)(1)(i)(A)-(C). Whereas the prior Walking-Working Surfaces standard required employers to implement guardrail systems to protect employees from falls, the updated regulation’s most significant revision, per OSHA, is “allowing employers to select the fall protection system that works best for them, … including personal fall protection systems.” The updated regulation contains the following compliance deadlines:

May 17, 2017

Employers must ensure workers exposed to fall hazards are trained on those hazards, and workers who use fall protection equipment are trained on that equipment

November 20, 2017

Employers must inspect and certify permanent anchorages for rope descent systems

November 19, 2018

Employers must install personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures

November 19, 2018

Employers must ensure existing fixed ladders over 24 feet, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system

November 18, 2036

Employers replace cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet


Read more Insight & Impact from May 2017:


IMPACT: OSHA's revised Walking-Working Surface standard is a significant change from its prior version. Employers subject to the General Industry Standards must be attentive to the revised standard. Because of the upcoming training and compliance requirements, employers should assess their workplaces and determine what changes, if any, to the workplace need to be performed. To assist employers, OSHA has published a Fact Sheet and FAQs.

For more information, please contact your local Quarles & Brady attorney or this member of our employee benefits group:

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