The long awaited Walking/Working Surfaces Subpart D


The long awaited revision of the WWS Subpart D has arrived, and did not disappoint. Hard to believe (?) that it took this much time but they did an excellent job bringing the fall protection requirements of general industry up to par with that of construction. Although virtually all companies have already aligned their programs to be consistent with 1926.500 Subpart M, it is nice to have general industry in the fold.


The effective date was January 17,2017, and all enforcement dates are now in effect, with the lone exception being the final implementation of fall protection on fixed ladders for another 20 years!

Let’s get to some of the key bullet points:

  1. Flat roofs: Great news on flat roofs! Finally firm numbers. 0-6’ fall protection required, 6-15’ warning lines acceptable. Beyond 15’, no additional requirements. NOTE: I RECOMMEND GUARDRAILS FOR ALL WORKERS WITHIN 15’

  2. Holes: Now follows construction standard. 2” least dimension. All holes must be covered when 4’ above wws.

  3. Low-sloped roof: Same as construction. Equal or less than 4:12

  4. 30” high, 18” wide

  5. Qualified Person: still the same, not the onerous ANSI definition.

  6. Strength of surface: Must support the intended load for that surface.

  7. Ladders: No major changes. No fall protection required. DON’T USE THEM.

  8. Step bolts: Strength and corrosion requirements for new installs

  9. Anchorages on buildings for suspended scaffolds. Must be 5,000 pounds, annual inspection, recertification at least every 10 years.

  10. Repair pits. New requirements.

  11. Fixed ladders. New installs after Nov 19,2018, must have ladder safety system or fall protection. All ladders after Nov 18,2036 must have LSS or FP. Mark your calendars!

  12. Outdoor Advertising: Qualified climber excuse going away.

  13. Guardrails: OK to go taller. DO IT! Must keep openings to l9”

  14. Handrail and Stair rails. Combo guardrail and handrail

  15. Ladder safety devices: Must be hands-free. (New ANSI STD does the same)

  16. Authorized User training: completed by May 17, 2017. Trained by a Qualified Trainer

  17. Snap hook gates must support 3600 pounds. Same as ANSI STD, but does not have to meet ANSI Std.

  18. Anchor Strength: 5000 or safety factor of two.

  19. Maximum force on worker: 1800 pounds.

  20. Shock absorber elongation: 42” Still conflicts with ANSI of 48”

https://www.osha.gov/walking-working-surfaces/

Questions? Give me a call.

Competent Person Class: Planning one in Kansas City, MO this year. Will do custom classes anywhere.

Mark S. Damon

Damon, Inc

816.896.1849

DamonFallProtection.com

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