While every company has different challenges when it comes to safety, some training best practices are consistent across industries. OSHA recently made changes to its Walking Working Surfaces standard for general industry. With this update, OSHA estimates that the final rule will prevent 29 worker deaths and 5,842 lost-workday injuries each year. By harmonizing general industry requirements with OSHA's existing construction industry standard and many ANSI standards, the new rule makes compliance easier and less costly.
Here’s a breakdown highlighting training changes in the new Walking-Working Surfaces standard for general industry.
A New Training Standard: 1910.130
Looking to industry best practices, OSHA drew most of the new training requirements from the current fall protection standard in construction. This new standard (1910.130) requires training specifically on:
- Fall hazards
- Equipment hazards
- Retraining (only in certain situations)
The final training requirements are performance based and give employers flexibility to tailor the requirements and training methods to their workforce and workplace. This implies that the length of the training is determined by the facility and situation.
One company might have employees in fall protection harnesses daily using a variety of lanyard/SRL options and anchor points. Such employee training would be more in-depth compared to an organization that may rarely have employees in a harness. Remember, you can’t simply hand a harness and a lanyard to an employee and expect him or her to know how to use and inspect it properly.
Training Tailored to Your Environment
This new standard specifically requires that employers train workers in the correct and safe use of personal fall protective systems and the limitation of those systems. While the training is not required to be “site-specific,” effective training needs to address the hazards which employees may be exposed to.
The regulation defines fall hazard as “any condition on a walking-working surface (WWS) that exposes an employee to a risk of harm from a fall on the same level or to a lower level.” For the purposes of most employers, “fall hazards” refer to the risk of falling 4 feet or more to a lower level, except for falling into or onto dangerous equipment. There is no limit to the distance allowed to fall in this exception.
It’s important to point out that many injuries can and do occur when employees slip, trip or fall when walking or working at ground level. For various production reasons, floors can be inherently slippery in certain parts of a plant, requiring management to train on these conditions and be extra diligent in enforcing housekeeping protocols.
With that said, the standard isn’t requiring special WWS training for those at ground level even though OSHA is very concerned about the injuries that can result from various floor conditions.
Implementing the New Standard Across Broad Areas
The scope of the final standard for training is broad; it requires that employers train all workers who use personal fall arrest systems and positioning systems. It also requires employers to train each worker who uses equipment covered by Subpart D in the proper use, inspection, care, maintenance, and storage of that equipment. The equipment includes, but is not limited to:
- Ladder safety systems
- Safety net systems
- Portable guardrail and mobile ladder stands and platforms
What about portable ladders? Employees are protected by the inspection, control, work practice, and design requirements in Subpart D. 1910.23, which specifies many design and work practice requirements for portable ladders. Under the final rule, employers are responsible for providing portable ladders that comply with the design requirements as well as ensuring that workers understand and follow work practices. You need to provide training to any and all workers who will be on a portable ladder.
The Timeline for Compliance
To give employers adequate time to develop and provide initial training, OSHA allowed 6 months for employers to train their workers in the new requirements. The deadline for compliance was May 17, 2017. If a company had already trained employees prior to this standard, that is acceptable as long as it is documented. However, many of the training requirements in final 1910.130(a) are new, so you should make sure all components have been covered. Many employers continually teach their employees on fall protection and ladder safety, so meeting these new training requirements shouldn’t be too difficult.
Qualified vs. Competent: Who Can Provide Training
The standard states that “the employer must ensure that each employee is trained by a qualified person.” This is different than the construction fall protection standard which states that a competent person is qualified to train workers in each of the items and topics specified. OSHA believes that, despite the differences in language between the terms, the standards are consistent with what they expect from the trainer.
Qualified Person: A person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience has successfully demonstrated the ability to solve or resolve problems related to the subject matter, the work, or the project.
Competent Person: One who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees and who has authorization to take prompt corrective measures to eliminate them.
The definition of “qualified” would allow employers to have crew chiefs, supervisors, operations personnel, or other individuals train workers providing they have the necessary knowledge, training, and experience. Being qualified doesn’t require possessing a degree.
Computer-Based Training Options and Concerns
OSHA clearly states in the preamble that employers are allowed to use outside personnel or computer-based training to train workers. Many companies don’t have the resources that meet the “qualified person” criteria.
The biggest concern of web or computer-based training is that:
- A qualified person developed or prepared the training;
- It complies with the requirements in 1910.130;
- It is delivered in a manner each worker understands; and
- A qualified person must be available to answer any worker questions.
Under this section of the training requirements, OSHA requires that employers train workers in all of the following areas:
- The proper care, inspection, storage, and use of equipment covered under the entire Walking-Working Surface standard
- How to properly place and secure dockboards to prevent unintentional movement
- How to properly rig and use a rope descent system (RDS)
- How to properly set up and use designated areas (flagging systems on low-sloped or flat roofs)
Essentially, this section applies to the extent that workers use equipment covered by Subpart D. Under this provision, employers must train workers in equipment, as well as fall protection systems, that the “fall hazards” section does not cover.
This covers equipment such as:
- Safety net systems
- Ladder safety systems
- Warning lines
- Portable guardrails
- Motorized materials handling equipment use on dockboards
According to the standard, an employer must retrain an employee when the employer has reason to believe that the employee does not have the understanding and skill required by paragraphs (a) and (b) of the training section. Some situations that might require retraining include:
- When workplace changes render previous training obsolete or inadequate
- When changes in the types of fall protection systems or equipment workers use renders previous training obsolete or inadequate
- When inadequacies in a worker’s knowledge or use of fall protection systems or equipment indicate that the worker does not have the requisite understanding or skill necessary to use the equipment or perform the job safely
Other signs pointing to retraining include a poor employee evaluation, near miss, or even an accident. These situations all justify requiring retraining.
Training Must Be Understandable
Simply stated, the standard says “the employer must provide information and training to each employee in a manner that the employee understands.” As an example, if a worker doesn’t speak or adequately comprehend English, the employer must provide training in a language that the worker understands. If a worker can’t read, employers will need to use a format to ensure that the worker understands the training they receive. Options could include:
- Audio-visual training
- Classroom instruction
- A hands-on approach
An increasing number of employers are using computer-based and web-based training. In these situations, the standard requires that workers have adequate computer skills. Employees must be able to operate the program and understand the information present. This is also why employers should make sure that a qualified person is available to answer questions and clarify information.
Stay Trained, Stay Protected
Keeping employees safe on the job starts with providing excellent training. This new Walking Working Surfaces standard clarifies an employer’s responsibility to its employees in terms of how often training should occur, who should provide training, and when retraining may be necessary.
While there are a variety of techniques in how the training is conducted, some elements of training apply across all companies in general industry. Follow the guidelines in the new standard and remember the following:
- Cover all aspects of training mentioned in the standard that apply to your operation.
- Document your training along with a description of what was covered.
- Make sure you have a written safety program in place for Walking-Working Surfaces.
- Record that you have inspected your facility and will continue to on a specific schedule.
Source: OSHA Federal Register/Vo. 81: pages 82637-82643