OSHA Proposed Rule Changes

How will the OSHA proposed Walking-Working Surfaces and Personal Protective Equipment rule affect the way your facility runs?  While first proposed in 1990, revised in 2003 and again in 2010, the final ruling was scheduled to be published last month.  According to an article entitled “Walking on Sunshine” by Karen D. Hamel, it is unclear if the final rule will make it into the Federal Registrar this year or not.  The article does a great job of explaining the proposed rule changes as well as giving practical, proactive suggestions on what facilities can do NOW in order to prepare for the final ruling when it does come.  Below are the suggestions for how you can prepare from www.ehstoday.com:

  • Facilities should be orderly and sanitary:
    • Section 29 CFR 1910.22(a)(1) of the prosed rule will remain exactly the same as the current regulation.  All areas of a facility must remain “clean, orderly, and in a sanitary condition.”  This does not mean that all areas of a facility need to be to food or pharmaceutical standards, they should just be kept in an orderly, clean, and safe manner.  Keeping your facility clutter free and making sure that hazards such as trash and excess waste make it to their designated disposal area will help ensure compliance.
  • Keep flooring dry and clean:
    • Proposed section [29 CFR 1910.22(a)(2)] states “not limited to the hazards of slips, trips and falls, but also addresses any hazard that can be created when floors and work areas are not maintained in an orderly, clean, dry and sanitary condition.”  If floors are consistently getting wet, OSHA allows for proactive measures such as mats, fans, drainage holes, mops, and squeegees to be use.
  • Flooring must remain hazard free:
    • Currently OSHA’s rule says that passageways, should be kept “free from protruding nails, splinters, holes or loose boards.”  The proposed rule will add a whole new level of proactive safety into keeping flooring free of hazards.  According to the proposal, safety professionals will, and should, have a greater opportunity to get involved in the design and construction part of renovations and new builds.  A safety professional may recognize a potential safety hazard and be able to help redesign or choose a different product in an attempt to prevent future incidents from happening.
    • SLIPNOT Metal Safety Flooring places a lot of emphasis on designing safety into facilities.  In fact, we offer an AIA/CES registered course entitled “Smart Safety Design to Prevent Slips, Trips and Falls.”  A SLIPNOT professional will visit your facility, bring refreshments, and teach you how to design safety into your plant.  Attendees receive 1 HSW LU.  If a course is not something you are interested in, non slip safety can be designed into any hazardous area that currently exists.  By simply contacting a SLIPNOT safety expert, a customized solution can be provided.
  • Regular maintenance must be performed:
    • A new requirement of the proposed rule states that floors need “regular and periodic” inspections. If problems or hazards are found they must be corrected.  It does not state a specific amount of inspections or a specific time period in which they should occur.  Each facility should determine what is best based upon their environment and flooring use.
  • Hazard correction must happen:
    • Proposed paragraph (d)(2)will require hazards once found, to be corrected in a timely manner.   Sometimes you will see a hazard sign around cracked flooring or holes in the cement for months or even years.  This proposed paragraph hopes to have these hazards fixed quickly and efficiently.
  • Qualifications are Important:
    • Proposed paragraph (d)(3) talks about making sure that anyone who does repairs on flooring is qualified in order to maintain safety standards.  If the structural integrity or load bearing properties of flooring are compromised during a repair or reconstructive project, a qualified professional must ensure that the end result will remain safe.
  • Training Requirements:
    • The newly proposed rule will add training requirements for employees.  Learning how to use PPE and identifying potential safety hazards need to be taught to all employees in order to maintain safety in the whole plant.

By familiarizing yourself with these current and proposed additions to OSHA’s rules you will help ensure OSHA compliance for your facility.

Hamel, Karen D. “Walking on Sunshine.” www.ehstoday.com September 7, 2016. October 17, 2016.

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