National Grain and Feed Association

NGFA Guidance Document for OSHA Walking-Working Surfaces 1910.22(D)

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Table of Contents

DEFINITIONS .................................................................................................................................................. 3

TRAINING REQUIREMENTS ........................................................................................................................... 5

SUBPART D REVISION TO FIXED LADDERS .................................................................................................... 7

LADDER REQUIRMENTS ............................................................................................................................... 7

LADDER ILLUSTRATIONS ............................................................................................................................. 15

STAIRCASE, HANDRAILS, STAIRRAILS, & GUARDRAILS ................................................................................ 27

FALL PROTECTION PROGRAM ..................................................................................................................... 37

UNDERSTANDING WALKING WORKING SURFACS FINAL RULE .................................................................. 38

FREQUENTLY ASKED QUESTIONS ................................................................................................................ 61

Legal Notice

The information presented in these materials covers a wide range of complex matters presented by various sources. The materials are for informational purposes only. NGFA makes no guarantees, assurances, or warranties, express or implied, concerning the accuracy, application, use or reliance upon the information contained in this material. Any responsibility for the use of this information is disclaimed. Further, nothing in this material is intended as legal advice. Competent counsel should be consulted on any legal issues.

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Changes to Walking Working Surfaces Training Requirements

Definitions:

Anchorage means a secure point of attachment for equipment such as lifelines, lanyards, deceleration devices, and rope descent systems.

Authorized means an employee who the employer assigns to perform a specific type of duty, or allows in a specific location or area.

Dockboard means a portable or fixed device that spans a gap or compensates for a difference in elevation between a loading platform and a transport vehicle. Dockboards include, but are not limited to, bridge plates, dock plates, and dock levelers.

Fall hazard means any condition on a walking-working surface that exposes an employee to a risk of

harm from a fall on the same level or to a lower level.

Fall protection means any equipment, device, or system that prevents an employee from falling from an elevation or mitigates the effect of such a fall.

Guardrail system means a barrier erected along an unprotected or exposed side, edge, or other area of a walking working surface to prevent employees from falling to a lower level.

Maximum intended load means the total load (weight and force) of all employees, equipment, vehicles, tools, materials, and other loads the employer reasonably anticipates to be applied to a walking-working surface at any one time.

Personal fall arrest system means a system used to arrest an employee in a fall from a walking-working surface. It consists of a body harness, anchorage, and connector. The means of connection may include a lanyard, deceleration device, lifeline, or a suitable combination of these.

Personal fall protection system means a system (including all components) an employer uses to provide protection from falling or to safely arrest an employee's fall if one occurs. Examples of personal fall protection systems include personal fall arrest systems, positioning systems, and travel restraint systems.

Platform means a walking-working surface that is elevated above the surrounding area.

Positioning system (work-positioning system) means a system of equipment and connectors that, when used with a body harness or body belt, allows an employee to be supported on an elevated vertical

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surface, such as a wall or window sill, and work with both hands free. Positioning systems also are called "positioning system devices" and "work-positioning equipment."

Qualified describes 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 relating to the subject matter, the work, or the project also are called "positioning system devices" and "work-positioning equipment."

Rope descent system means a suspension system that allows an employee to descend in a controlled manner and, as needed, stop at any point during the descent. A rope descent system usually consists of a roof anchorage, support rope, a descent device, carabiner(s) or shackle(s), and a chair (seatboard). A rope descent system also is called controlled descent equipment or apparatus. Rope descent systems do not include industrial rope access systems.

Travel restraint system means a combination of an anchorage, anchorage connector, lanyard (or other means of connection), and body support that an employer uses to eliminate the possibility of an employee going over the edge of a walking-working surface.

Unprotected sides and edges mean any side or edge of a walking-working surface (except at entrances and other points of access) where there is no wall, guardrail system, or stair rail system to protect an employee from falling to a lower level.

Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.

Warning line means a barrier erected to warn employees that they are approaching an unprotected side or edge, and which designates an area in which work may take place without the use of other means of fall protection.

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Training Requirements:

29 CFR 1910.27

Use of rope descent systems

The employer must ensure: No rope descent system is used for heights greater than 300 feet (91 m) above grade

unless the employer demonstrates that it is not feasible to access such heights by any other means or that those means pose a greater hazard than using a rope descent system;

The rope descent system is used in accordance with instructions, warnings, and design limitations set by the manufacturer or under the direction of a qualified person;

Each employee who uses the rope descent system is trained in accordance with § 1910.30;

29 CFR 1910.28

Unprotected sides and edges

When the employer can demonstrate that the use of fall protection systems is not feasible on the working side of a platform used at a loading rack, loading dock, or teeming platform, the work may be done without a fall protection system, provided:

The work operation for which fall protection is infeasible is in process; Access to the platform is limited to authorized employees; and, The authorized employees are trained in accordance with § 1910.30.

Dockboards

The employer must ensure that each employee on a dockboard is protected from falling 4 feet (1.2 m) or more to a lower level by a guardrail system or handrails. A guardrail system or handrails are not required when:

Dockboards are being used solely for materials-handling operations using motorized equipment;

Employees engaged in these operations are not exposed to fall hazards greater than 10 feet (3 m); and

Those employees have been trained in accordance with § 1910.30.

Slaughtering facility platforms

The employer must protect each employee on the unprotected working side of a slaughtering facility platform that is 4 feet (1.2 m) or more above a lower level from falling by using:

Guardrail systems; or

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Travel restraint systems. When the employer can demonstrate the use of a guardrail or travel restraint system is not

feasible, the work may be done without those systems provided: The work operation for which fall protection is infeasible is in process; Access to the platform is limited to authorized employees; and The authorized employees are trained in accordance with § 1910.30.

29 CFR 1910.30

Fall hazards

Before any employee is exposed to a fall hazard, the employer must provide training for each employee who uses personal fall protection systems or who is required to be trained as specified elsewhere in this subpart. Employers must ensure employees are trained in the requirements of this paragraph on or before May 17, 2017. The employer must ensure that each employee is trained by a qualified person. The employer must train each employee in at least the following topics:

The nature of the fall hazards in the work area and how to recognize them; The procedures to be followed to minimize those hazards; The correct procedures for installing, inspecting, operating, maintaining, and

disassembling the personal fall protection systems that the employee uses; and The correct use of personal fall protection systems and equipment specified in

paragraph (a)(1) of this section, including, but not limited to, proper hook-up, anchoring, and tie-off techniques, and methods of equipment inspection and storage, as specified by the manufacturer.

Equipment hazards

The employer must train each employee on or before May 17, 2017 in the proper care, inspection, storage, and use of equipment covered by this subpart before an employee uses the equipment. The employer must train each employee who uses a dockboard to properly place and secure it to prevent unintentional movement. The employer must train each employee who uses a rope descent system in proper rigging and use of the equipment in accordance with § 1910.27. The employer must train each employee who uses a designated area in the proper set-up and use of the area.

Retraining

The employer must retrain an employee when the employer has reason to believe the employee does not have the understanding and skill required by paragraphs (a) and (b) of this section. Situations requiring retraining include, but are not limited to, the following:

When changes in the workplace render previous training obsolete or inadequate;

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When changes in the types of fall protection systems or equipment to be used render previous training obsolete or inadequate; or

When inadequacies in an affected employee's knowledge or use of fall protection systems or equipment indicate that the employee no longer has the requisite understanding or skill necessary to use equipment or perform the job safely.

Training must be understandable

The employer must provide information and training to each employee in a manner that the employee understands.

SUBPART D AND FIXED LADDERS OSHA’s revision to Subpart D involves a complete reorganization of the topics contained in this Subpart. The specific standards within this Subpart have been both renamed and renumbered. Prior to the revision of Subpart D there was a standard pertaining to fixed ladders, specifically 29 CFR 1910.27. Everything you needed to know about fixed ladders was contained in this standard. The revised Subpart D no longer has a standard specific to fixed ladders. The requirements for fixed ladders are now scattered between three different standards. This document is intended to bring all of these requirements together to assist with compliance.

The American National Standards Institute (ANSI) also has a standard addressing the safety requirements for fixed ladders. The standard number is ANSI A14.3-2008. Unlike OSHA, the ANSI standard provides much greater detail and information regarding the design details for fixed ladders. ANSI covers items such as live load and dead load requirements, specifies material type, cross section size and thickness, fabrication methods, shapes and much more.

When reviewing each of the specific requirements for fixed ladders in OSHA’s revised Subpart D, the ANSI standard was also reviewed to compare the requirements of each. The requirements for fixed ladders between OSHA and ANSI are virtually identical with a few minor differences. These differences do not affect compliance with the OSHA standard and will be outlined later in the document. As you review each of the OSHA standards for fixed ladders (those starting with the numbers 1910) the equivalent ANSI standard will also be referenced in italicized type.

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OSHA’s fixed ladder standards relative to design and installation parameters provide minimal information and graphic examples when compared to the ANSI standard. Whether considering fixed ladder designs for an existing or new facility or when contracting out the purchase and installation of new or repaired fixed ladders, it may be best to specify that the ladders comply with the above referenced ANSI standard as it will also comply with OSHA.

1910.23 Ladder Requirements Application The employer must ensure that each ladder used meets the requirements of this section. This section covers all ladders, except when the ladder is: 1910.23(a)(1) – Used in emergency operations such as firefighting, rescue, tactical law enforcement operations or training for these operations. Not addressed in ANSI 1910.23(a)(2) - Designed into or is an integral part of machines or equipment. Not addressed in ANSI General Requirements for all Ladders 1910.23(b)(1) – The employer must ensure ladder rungs, steps and cleats are parallel, level and uniformly spaced when the ladder is in position for use. ANSI 5.1.3.1(e) 1910.23(b)(2) – Ladder rungs, steps and cleats are spaced not less than 10 inches and not more than 14 inches apart as measured between the centerlines of the rungs, cleats and steps. ANSI 5.1.1 allows 1st rung to be adjusted to a maximum height of 14 inches with remaining rungs are spaced 12 inches apart and uniform. (See Illustration #6) 1910.23(b)(4) – Ladder rungs, steps and cleats must have a minimum clear width (distance between side rails) of 16 inches (measured before installation of ladder safety systems) for fixed ladders. ANSI 5.1.2 (See Illustration #6) 1910.23(b)(6) – Metal ladders are made with corrosion-resistant material or protected against corrosion. ANSI 5.6 – provides more specific details. 1910.23(b)(7) – Ladder surfaces are free of puncture and laceration hazards. ANSI 4.1.5 1910.23(b)(8) – Ladders are used only for the purposes for which they were designed. Not specifically addressed in ANSI as this is implied. 1910.23(b)(9) – Ladders are inspected before initial use in each work shift and more frequently as necessary to identify any visible defects that could cause employee injury. ANSI 9.1.4 requires fixed ladders to be routinely inspected to ensure they comply with the requirements of the standard. ANSI

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9.3.1 further requires fixed ladders and ladder safety systems be inspected for rust, corrosion and deterioration at least annually with more frequent inspection determined by the employer. Refer to Section VII of ladder analysis for further details. 1910.23(b)(10) – Any ladder with structural or other defects is immediately tagged “Dangerous: Do Not Use” or with similar language in accordance with 1910.145 and removed from service until repaired in accordance with 1910.22 or replaced. ANSI 9.3.3 1910.23(b)(11) – Each employee faces the ladder when climbing up or down it. ANSI 9.2.1 1910.23(b)(12) – Each employee uses at least one hand to grasp the ladder when climbing up and down it. ANSI 9.2.1 1910.23(b)(13) – No employee carries any object or load that could cause the employee to lose balance and fall while climbing up or down a ladder. ANSI 9.2.2 Requirements for Fixed Ladders 1910.23(d)(1) – The employer must ensure fixed ladders are capable of supporting their maximum intended load. ANSI 4.2 1910.23(d)(2) – The minimum perpendicular distance from the centerline of the steps or rungs, or grab bars, or both, to the nearest permanent object in back of the ladder is 7 inches. ANSI 5.4.2 (See Illustration #7) 1910.23(d)(3) – Grab bars do not protrude on the climbing side beyond the rungs of the ladder that they serve. ANSI 5.4.2.1 1910.23(d)(4) – The side rails of through or sidestep ladders extend 42 inches above the top of the access level or landing platform served by the ladder. ANSI 5.3.2.1 (See Illustrations #6 and #8) For parapet ladders the access level is: 1910.23(d)(4)(i) – The roof if the parapet is cut to permit passage through the parapet. ANSI 5.3.2.1 Fig.10 (See Illustration #10) 1910.23(d)(4)(ii) – The top of the parapet if the parapet is continuous. ANSI 5.3.2.1 Fig.10

(See Illustration #10) 1910.23(d)(5) – For through ladders, the steps or rungs are omitted from the extensions, and the side rails are flared to provide not less than 24 inches and not more than 30 inches of clearance. ANSI 5.3.2.2 Fig. 9 When a ladder safety system is provided, the maximum clearance between the side rails of the extension must not exceed 36 inches. This last sentence is not specifically addressed in ANSI but if you follow the first part you will comply.

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1910.23(d)(6) – For side-step ladders, the side rails, rungs, and steps must be continuous in the extension. (OSHA Figure D-2) ANSI 5.3.2.3 Fig. 6 (See Illustration #6) 1910.23(d)(7) – Grab bars extend 42 inches above the access level or landing platforms served by the ladder. ANSI 5.3.3.2 and ANSI 5.3.4.3 for hatch openings. 1910.23(d)(8) – The minimum size (cross-section) of grab bars is the same size as the rungs of the ladder. ANSI 5.3.3.3 1910.23(d)(9)(i) – When a fixed ladder terminates at a hatch (OSHA Figure D-3) the hatch cover must open with sufficient clearance to provide easy access to or from the ladder. Note: OSHA Fig. D-3 shows a hatch opening of 30 inches of clearance with no other options for unusual situations yet the standard states “sufficient clearance”. What exactly is sufficient clearance may be clarified in the compliance directive. ANSI 5.3.4.1 Fig. 13 allows for a minimum opening of 27 inches and a maximum opening of 30 inches. It also allows for unusual hatch conditions where the opening may be reduced to no less than 24 inches provided a deflector plate is installed. It could be argued that the clearances in ANSI are “sufficient” to provide safe access to and from the ladder. (See Illustration #11) 1910.23(d)(9)(iii) – The hatch must open at least 70 degrees from horizontal if the hatch is counterbalanced. ANSI 5.3.4.2 1910.23(d)(10) – Individual rung ladders are constructed to prevent the employee’s feet from sliding off the ends of the rungs. (OSHA Figure D-4) ANSI Fig. 8 (See Illustration #14) 1910.23(d)(11) – Fixed ladders having a pitch greater than 90 degrees from the horizontal are not used. ANSI 1.4.3 Step-Across Distance 1910.23(d)(12)(i) – The step-across distance from the centerline of the rungs or steps for through ladders is not less than 7 inches and not more than 12 inches to the nearest edge of the structure, building, or equipment accessed from the ladder. ANSI 5.4.2.2 1910.23(d)(12)(ii) - The step-across distance from the centerline of the rungs or steps for side-step ladders is not less than 15 inches and not more than 20 inches to the access points of the platform edge. ANSI 5.4.3.2 (See Illustration #6) Fixed Ladders Without Cages or Wells 1910.23(d)(13)(i) – Fixed ladders that do not have cages or wells must have a clear width of at least 15 inches on each side of the ladder centerline to the nearest permanent object. ANSI 5.4.3.1 (See Illustration #6) 1910.23(d)(13)(ii) – Fixed ladders that do not have cages or wells must have a minimum perpendicular distance of 30 inches from the centerline of the steps or rungs to the nearest object on the climbing

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side. When unavoidable obstructions are encountered, the minimum clearance at the obstruction may be reduced to 24 inches provided deflector plates are installed. (OSHA Figure D-5) ANSI 5.4.1.1 and 5.4.1.3 Fig. 15 (See Illustration #7)

1910.28 Duty to Have Fall Protection and Falling Object Protection

Protection From Falls 1910.28(b)(3)(iv) – Each employee is protected from falling into a ladderway floor hole or ladderway platform hole by a guardrail system and toeboards erected on all exposed sides, except at the entrance to the hole where a self-closing gate or an offset must be used. ANSI 4.1.4.1(b) Fig. 5a (See Illustration #5) Fixed Ladders Extending More Than 24 Feet Above a Lower Level 1910.28(b)(9)(i) – Fixed ladders that extend more than 24 feet or expose a worker to a fall of more than 24 feet to a lower level must adhere to the following: Existing Fixed Ladders 1910.28(b)(9)(i)(A) – Employer must ensure each existing fixed ladder installed before November 19, 2018 that extends more than 24 feet or exposes a worker to a fall of more than 24 feet to a lower level is equipped with a personal fall arrest system or; ladder safety system or; cage or well. ANSI 4.1.1 has the same requirement as OSHA but does not have the specific implementation date which applies only to OSHA. (See Illustration #2) New Fixed Ladders 1910.28(b)(9)(i)(B) – Each fixed ladder installed on or after November 19, 2018 must be equipped with a personal fall arrest system or a ladder safety system. Note: Safety cages are not required but may be installed by the employer as long as they do not interfere with the operation of the personal fall arrest or ladder safety system. ANSI 4.1.3 requires a ladder safety system but does not mention the use of personal fall arrest systems. ANSI does not have the specific compliance date. (See Illustration #4) Replacing Ladders after November 19, 2018 1910.28(b)(9)(i)(C) – When a fixed ladder, cage or well, or any portion or section thereof is replaced, a personal fall arrest system or a ladder safety system must be installed in at least that section of the fixed ladder, cage or well where the replacement is located. ANSI 1.6.2. Refer to Section IV of ladder analysis for further details. Final Deadline 1910.28(b)(9)(i)(D) – On and after November 18, 2036, all fixed ladders must be equipped with a personal fall arrest system or a ladder safety system. Note: Safety cages and wells are no longer

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required. [See 1910.28(b)(9)(iv) below.] ANSI does not have a compliance deadline as ANSI standards are voluntary and not required. Single or Multiple Section Ladders With Fall Protection or Ladder Safety Systems 1910.28(b)(9)(ii)(A) – The employer must ensure that personal fall arrest systems or ladder safety systems provide protection throughout the entire vertical distance of the ladder, including all ladder sections. ANSI does not address this specific requirement. With regard to the installation of new ladders and modification or replacement of existing ladders, compliance with the requirements of the standard are implied. 1910.28(b)(9)(ii)(B) – The employer must ensure the ladder has rest platforms provided at maximum intervals of 150 feet. ANSI 4.1.4.2 (See Illustration #4) Ladder Sections With Safety Cages or Wells Installed Before November 19, 2018 1910.28(b)(9)(iii)(A) – The employer must ensure ladders are offset from adjacent sections. ANSI 4.1.4.1(a). 1910.28(b)(9)(iii)(B) – The employer must ensure ladders have landing platforms provided at maximum intervals of 50 feet. ANSI 4.1.4.1(b) and ANSI Fig. 5a. (See Illustration #3) 1910.28(b)(9)(iv) – The employer may use a cage or well in combination with a personal fall arrest system or ladder safety system provided that the cage or well does not interfere with the operation of the system. ANSI 4.1.6 states ladder safety systems may be used in conjunction with a cage. It does not state that the cage must not interfere with the operation of the system as this is implied.

1910.29 Fall Protection Systems and Falling Object Protection Criteria and Practices

Safety Cages, Wells and Platforms used with Fixed Ladders 1910.29(g)(1) – The employer must ensure that cages and wells installed on fixed ladders are designed, constructed and maintained to permit easy access to, and egress from, the ladder that they enclose. (OSHA Figures D-14 and D-15) Note: Figure D-15 is the exact same figure from the previous standard and has inaccurate information as it shows the maximum cage length being 30 feet whereas the revised standard now allows a ladder with a cage to have a maximum length of 50 feet. [1910.28(b)(9)(iii)(B)] ANSI Figures 17 and 18 are essentially the same as OSHA. OSHA lists a cage diameter of 27 inches whereas ANSI allows for a cage diameter of between 27 - 30 inches which will comply with OSHA. (See Illustration #12)

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1910.29(g)(2) – Cages and wells must be continuous throughout the length of the fixed ladder, except for access, egress, and other transfer points. ANSI does not specifically state this however when looking at the various figures this is implied. 1910.29(g)(3) – Cages and wells are designed, constructed and maintained to contain employees in the event of a fall, and to direct them to a lower landing. ANSI does not specifically state this however when looking at the various figures this is implied. 1910.29(g)(4) – Platforms used with fixed ladders provide a horizontal surface of at least 24 inches by 30 inches. ANSI 6.3.2 requires platforms to have a depth of 30 inches minimum from the centerline of the ladder on the climbing side and a width not less than 30 inches. Since these dimensions are not less than OSHA’s the ANSI standard will comply. Ladder Safety Systems 1910.29(i)(1) – Employers must ensure that each ladder safety system allows the employee to climb up and down using both hands and does not require that the employee continuously hold, push, or pull any part of the system while climbing. ANSI 7.3.1 1910.29(i)(2) – The connection between the carrier or lifeline and the point of attachment to the body harness or belt does not exceed 9 inches. ANSI 7.3.3 (See Illustration #13) 1910.29(i)(3) – Mountings for ridged carriers are attached at each end of the carrier, with intermediate mountings spaced, as necessary, along the entire length of the carrier so the system has the strength to stop employee falls. ANSI 7.3.4 1910.29(i)(4) – Mountings for flexible carriers are attached at each end of the carrier and cable guides for flexible for flexible carriers are installed at least 25 feet apart but not more than 40 feet apart along the entire length of the carrier. ANSI 7.3.5 1910.29(i)(5) – The design and installation of mountings and cable guides does not reduce the design strength of the ladder. ANSI 7.1.4 1910.29(i)(6) – Ladder safety systems and their support systems are capable of withstanding, without failure, a drop test consisting of an 18 inch drop of a 500 pound weight. ANSI 7.1.3 Personal Fall Protection Systems 1910.29(j) – Body belts, harnesses and other components used in personal fall arrest systems, work positioning systems and travel restraint systems must meet the requirements of 1910.140 Personal Fall Protection Systems. The ANSI fixed ladder standard makes reference to specific ANSI standards that cover fall arrest systems, harnesses, ladder safety systems, work positioning systems, hardware, anchor points, etc. which are covered in 1910.140. Note: These ANSI standards provide far more information and details regarding the design, construction, materials, load test requirements, etc. than OSHA 1910.140 and all fall protection equipment manufacturers follow these ANSI standards.

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Grab Handles 1910.29(l)(1) – The employer must ensure that each grab handle is not less than 12 inches long. ANSI does not address or use the term “Grab Handle” anywhere in the standard but does use the term “Grab Bar” and provides Figure 11 which shows examples of both horizontal and vertical grab bars. There are four instances in the OSHA standard where the term “Grab Bar” is used and all four of these requirements are the same as ANSI. OSHA standard 1910.21 titled Scope and Definitions defines the term “Grab Bar” but does not define “Grab Handle” so it is unclear what if any differences there are between the two. OSHA also does not provide an illustration or picture to reference these specific requirements. (See Illustration #9) 1910.29(l)(2) – Is mounted to provide at least 3 inches of clearance from the framing or opening. ANSI – See above comments. 1910.29(l)(3) – Is capable of withstanding a maximum horizontal pull-out force equal to two times the maximum intended load or 200 pounds whichever is greater. ANSI – See above comments.

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LADDER ILLUSTRATIONS

Illustration #1

Ladder or Fall to Lower Level 24 Feet or Less - Cage, Well or Ladder Safety System Not Required

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Illustration #2

Elevated Access with Ladder 24 Feet or Less but Fall Distance Greater Than 24 Feet for Existing Ladders Installed Before November 19, 2018:

Safety Cage, Well, Ladder Safety System or Personal Fall Arrest System Required

*NOTE: By November 18, 2036 these ladders must have ladder safety systems or personal fall arrest systems installed and employees required to use them as safety cages and wells are no longer required.

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Illustration #3 Ladder Sections Greater Than 24 Feet up to 50 Feet Maximum Installed Before November 19, 2018: Safety Cages, Wells, Ladder Safety System or Personal Fall Arrest System Required

Each Section. Offset Ladder Sections with Rest Platform Required at 50 Foot Maximum Intervals.

*NOTE: By November 18, 2036 these ladders must have ladder safety systems or personal fall arrest systems installed and employees required to use them as safety cages and wells are no longer required.

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Safety cages can be installed or left on older existing ladders as long as they do not interfere with operation of ladder or personal fall arrest system.

Illustration #4

New Fixed Ladders Installed On or After November 19, 2018 Must Have Ladder Safety Systems or Personal Fall Arrest Systems Installed

*NOTE: Safety cages, wells and offset ladder sections are no longer required for fixed ladders installed on or after November 19, 2018. Safety cages can be installed as long as they do not interfere with operation of ladder or personal fall arrest system.

Illustration #5

Example of Fixed Ladder Rest Platform and Guarding of Ladderway

Entrance/Exits to Walkways and Work Platforms

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Illustration #6

Ladder Dimensions, Side Clearances and Supports

Note requirement for self-closing gate.

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Illustration #7

Minimum Ladder Clearances and Floor, Platform, Roof or Other Obstructions

Illustration #8

Termination at Floor or Platform for Through Ladders

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Illustration #9

Horizontal and Vertical Grab Bar Extensions

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Illustration #10

Ladder Terminations at Roof and Parapets

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Illustration #11

Counterbalanced Hatch Cover at Roof

Normal Clearance Reduced Clearance

Illustration #12

Safety Cage Construction

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25

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Illustration #13

Connection Length Between Carrier and Safety Sleeve

Illustration #14

Individual Rung Ladder

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Staircase, Handrails, Stair Rails and Guardrails

Definitions

Stairway (stairs) means risers and treads that connect one level with another, and includes any landings and platforms in between those levels. Stairways include standard, spiral, alternating tread-type, and ship stairs.

Standard Stairs means a fixed or permanently installed stairway. Ship, spiral, and alternating tread-type stairs are not considered standard stairs.

Stair rail or stair rail system means a barrier erected along the exposed or open side of stairways to prevent employees from falling to a lower level.

Stairways 29 CFR 1910.25

Changed “Fixed Industrial Stair” to “Standard Stairs Vertical clearance above any stair tread to any overhead obstruction is at least 6 feet, 8 inches

(203 cm), as measured from the leading edge of the tread. Spiral stairs must meet the vertical clearance requirements in paragraph (d)(3) of this section.

Stairs have uniform riser heights and tread depths between landings;

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Stairway landings and platforms are at least the width of the stair and at least 30 inches (76 cm) in depth, as measured in the direction of travel; This change is almost the same to old standard.

When a door or a gate opens directly on a stairway, a platform is provided, and the swing of the door or gate does not reduce the platform's effective usable depth to:

o Less than 20 inches (51 cm) for platforms installed before January 17, 2017; and

o Less than 22 inches (56 cm) for platforms installed on or after January 17, 2017 (see Figure D-7 of this section);

Each stair can support at least five times the normal anticipated live load, but never less than a

concentrated load of 1,000 pounds (454 kg) applied at any point; this change is almost the same but the difference is that it applies to all stairs covered by this section.

Standard stairs are used to provide access from one walking-working surface to another when operations necessitate regular and routine travel between levels, including access to operating platforms for equipment. Winding stairways may be used on tanks and similar round structures when the diameter of the tank or structure is at least 5 feet (1.5 m).

Spiral, ship, or alternating tread-type stairs are used only when the employer can demonstrate that it is not feasible to provide standard stairs.

Spiral, ship, or alternating tread-type stairs are used only when the employer can demonstrate that it is not feasible to provide standard stairs.

When paragraph (b)(8) of this section allows the use of spiral, ship, or alternating tread-type stairs, they are installed, used, and maintained in accordance with manufacturer's instructions.

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Standard stairs. In addition, the employer must ensure standard stairs:

Are installed at angles between 30 to 50 degrees from the horizontal;

Have a maximum riser height of 9.5 inches (24 cm); (Exceptions apply to standard stairs installed prior to January 17, 2017.)

Have a minimum tread depth of 9.5 inches (24 cm); (Exceptions apply to standard stairs installed prior to January 17, 2017.) and

Have a minimum width of 22 inches (56 cm) between vertical barriers (see Figure D-8 of this section).

Table D-1 -- Stairway Rise and Tread Dimensions

Angle to horizontal Rise (in inches) Tread run (in inches)

30 deg. 35' 6 1/2 11

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Angle to horizontal Rise (in inches) Tread run (in inches)

32 deg. 08' 6 3/4 10 3/4

33 deg. 41' 7 10 1/2

35 deg. 16' 7 1/4 10 1/4

36 deg. 52' 7 1/2 10

38 deg. 29' 7 3/4 9 3/4

40 deg. 08' 8 9 1/2

41 deg. 44' 8 1/4 9 1/4

43 deg. 22' 8 1/2 9

45 deg. 00' 8 3/4 8 3/4

46 deg. 38' 9 8 1/2

48 deg. 16' 9 1/4 8 1/4

49 deg. 54' 9 1/2 8

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Spiral stairs. In addition, the employer must ensure spiral stairs:

Have a minimum clear width of 26 inches (66 cm);

Have a maximum riser height of 9.5 inches (24 cm);

Have a minimum headroom above spiral stair treads of at least 6 feet, 6 inches (2 m), measured from the leading edge of the tread;

Have a minimum tread depth of 7.5 inches (19 cm), measured at a point 12 inches (30 cm) from the narrower edge;

Have a uniform tread size;

Ship stairs. In addition, the employer must ensure ship stairs (see Figure D-9 of this section):

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Are installed at a slope of 50 to 70 degrees from the horizontal;

Have open risers with a vertical rise between tread surfaces of 6.5 to 12 inches (17 to 30 cm); Have minimum tread depth of 4 inches (10 cm); and

Have a minimum tread width of 18 inches (46 cm).

Alternating tread-type stairs, the employer must ensure alternating tread-type stairs:

Have a series of treads installed at a slope of 50 to 70 degrees from the horizontal;

Have a distance between handrails of 17 to 24 inches (51 to 61 cm);

Have a minimum tread depth of 8.5 inches (22 cm); and

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Have open risers if the tread depth is less than 9.5 inches (24 cm);

Have a minimum tread width of 7 inches (18 cm), measured at the leading edge of the tread

(i.e., nosing).

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Handrails/Stair rails/Guardrails

Definitions

Guardrail system means a barrier erected along an unprotected or exposed side, edge, or other area of a walking-working surface to prevent employees from falling to a lower level.

Handrail means a rail used to provide employees with a handhold for support.

Stair rail or stair rail system means a barrier erected along the exposed or open side of stairways to prevent employees from falling to a lower level.

Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work areas or workplace locations. (This is a change from “floor”)

Runways and similar walkways be protected with a guardrail when there is a fall exposure of 4’ or more. There are exceptions to the rule when the employer can show the operations require the omission. The employer must then provide other means of fall protection.

Dangerous Equipment where employees can fall into regardless to the fall height must be protected with handrail or travel restraint system, unless the equipment is guarded.

Openings. The employer must ensure that each employee on a walking-working surface near an opening, including one with a chute attached, where the inside bottom edge of the opening is less than 39 inches (99 cm) above that walking-working surface and the outside bottom edge of the opening is 4 feet (1.2 m) or more above a lower level is protected from falling by the use of:

Guardrail systems; Safety net systems; Travel restraint systems; or, Personal fall arrest systems.

Repair, service, and assembly pits (pits) less than 10 feet in depth. Repair, service, and assembly pits less than 10 feet (3 m) deep need not be protected by a fall protection system provided that the following requirements are met:

Access to any area within 6 feet (1.8 m) of the edge of the pit is limited to trained, authorized employees;

Floor markings in colors contrasting to that of the surrounding area are applied, or rope, wire, or chain with support stanchions meeting the requirements of Sec. 1910.29(d), or a

combination of these are placed at a distance of at least 6 feet (1.8 m) from the edge of the pit; and,

Caution signs stating, ``Caution--Open Floor,'' or a similar legend, are posted so that they are readily visible to employees entering the pit area.

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Guardrail systems The employer must ensure guardrail systems meet the following requirements:

The top edge height of top rails, or equivalent guardrail system members, are 42 inches (107 cm), plus or minus 3 inches (8 cm), above the walking-working surface. The top edge height may exceed 45 inches (114 cm), provided the guardrail system meets all other criteria of this section.

Midrails, screens, mesh, intermediate vertical members, solid panels, or equivalent intermediate members are installed between the walking-working surface and the top edge of the guardrail system as follows when there is not a wall or parapet that is at least 21 inches (53 cm) high:

o Midrails are installed at a height midway between the top edge of the guardrail system and the walking-working surface;

o Screens and mesh extend from the walking-working surface to the top rail and along the entire opening between top rail supports;

o Intermediate vertical members (such as balusters) are installed no more than 19 inches (48 cm) apart; and

o Other equivalent intermediate members (such as additional midrails and architectural panels) are installed so that the openings are not more than 19 inches (48 cm) wide.

Guardrail systems are capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied in a downward or outward direction within 2 inches (5 cm) of the top edge, at any point along the top rail.

o When the 200-pound (890-N) test load is applied in a downward direction, the top rail of the guardrail system must not deflect to a height of less than 39 inches (99 cm) above the walking-working surface.

Steel banding and plastic banding are not used for top rails or midrails. Top rails and midrails are at least 0.25-inches (0.6 cm) in diameter or in thickness.

Handrails and stair rail systems The employer must ensure:

Height criteria. Handrails are not less than 30 inches (76 cm) and not more than 38 inches (97 cm), as

measured from the leading edge of the stair tread to the top surface of the handrail. The height of stair rail systems meets the following:

The height of stair rail systems installed before January 17, 2017 is not less than 30 inches (76 cm) from the leading edge of the stair tread to the top surface of the top rail; and

The height of stair rail systems installed on or after January 17, 2017 is not less than 42 inches (107 cm) from the leading edge of the stair tread to the top surface of the top rail.

The top rail of a stair rail system may serve as a handrail only when:

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The height of the stair rail system is not less than 36 inches (91 cm) and not more than 38 inches (97 cm) as measured at the leading edge of the stair tread to the top surface of the top rail and

The top rail of the stair rail system meets the other handrail requirements above and were installed before January 17, 2017.

Finger clearance. The minimum clearance between handrails and any other object is 2.25 inches (5.7 cm).

Surfaces. Handrails and stair rail systems are smooth-surfaced to protect employees from injury, such as punctures or lacerations, and to prevent catching or snagging of clothing.

Openings in stair rails. No opening in a stair rail system exceeds 19 inches (48 cm) at its least dimension.

Handhold. Handrails have the shape and dimension necessary so that employees can grasp the handrail firmly.

Projection hazards. The ends of handrails and stair rail systems do not present any projection hazards.

Strength criteria. Handrails and the top rails of stair rail systems are capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied in any downward or outward direction within 2 inches (5 cm) of any point along the top edge of the rail.

FALL PROTECTION PROGRAM

Walking/Working Surfaces, Outside of Guarded Areas, and Rail Loading

The purpose of this Fall Protection Program is to prevent falls from elevations. This program is designed to meet the requirements of 29 Code of Federal Regulation (CFR) 1910.132, 1910.23 and 1926.502

Fall protection will be provided when employees work at heights over four feet. Protection from falls can be accomplished by applying engineering controls such as construction of barriers (such as railings) or other measures to prevent employee exposure to hazards, which is the preferred method, or by controlling the hazard with the use of personal fall protection equipment.

The final rule became effective on January 17, 2017, which is 60 days after publication in the Federal Register. OSHA also provides delayed or phased-in compliance dates for several requirements in the final rule, including:

Training workers on fall and equipment hazards -- 6 months;

Inspection and certification of permanent building anchorages -- 1 year;

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Installation of fall protection (personal fall arrest systems, ladder safety systems, cages, wells) on existing fixed ladders (over 24 feet) that do not have any fall protection -- 2 years;

Installation of ladder safety or personal fall arrest systems on new fixed ladders (over 24 feet) and replacement ladders/ladder sections -- 2 years; and

Installation of ladder safety systems or personal fall arrest systems on all fixed ladders (over 24 feet) – 20 years.

Rope descent systems (RDS) and certification of anchorages (§1910.27(b)).

The final rule codifies OSHA's memorandum for employers who use RDS to perform elevated work. The final rule prohibits employers from using RDS 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. In addition, the final rule requires building owners to provide and employers to obtain information that permanent anchorages used with RDS have been inspected, tested, certified, and maintained as capable of supporting at least 5,000 pounds per employee attached. 1910.27(b)

Anchorages 1910.27(b)(1)

Before any rope descent system is used, the building owner must inform the employer, in writing that the building owner has identified, tested, certified, and maintained each anchorage so it is capable of supporting at least 5,000 pounds (268 kg), in any direction, for each employee attached. The information must be based on an annual inspection by a qualified person and certification of each anchorage by a qualified person, as necessary, and at least every 10 years. 1910.27(b)(1)(i)

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The employer must ensure that no employee uses any anchorage before the employer has obtained written information from the building owner that each anchorage meets the requirements of paragraph (b)(1)(i) of this section. The employer must keep the information for the duration of the job. 1910.27(b)(1)(ii)

The requirements in paragraphs (b)(1)(i) and (ii) of this section must be implemented no later than November 20, 2017. 1910.27(b)(1)(iii)

Use of rope descent systems. The employer must ensure: 1910.27(b)(2)

No rope descent system is used for heights greater than 300 feet (91 m) above grade unless the employer demonstrates that it is not feasible to access such heights by any other means or that those means pose a greater hazard than using a rope descent system; 1910.27(b)(2)(i)

The rope descent system is used in accordance with instructions, warnings, and design limitations set by the manufacturer or under the direction of a qualified person; 1910.27(b)(2)(ii)

Each employee who uses the rope descent system is trained in accordance with § 1910.30; 1910.27(b)(2)(iii)

The rope descent system is inspected at the start of each workshift that it is to be used. The employer must ensure damaged or defective equipment is removed from service immediately and replaced; 1910.27(b)(2)(iv)

The rope descent system has proper rigging, including anchorages and tiebacks, with particular emphasis on providing tiebacks when counterweights, cornice hooks, or similar non-permanent anchorages are used; 1910.27(b)(2)(v)

Each employee uses a separate, independent personal fall arrest system that meets the requirements of subpart I of this part; 1910.27(b)(2)(vi)

All components of each rope descent system, except seat boards, are capable of sustaining a minimum rated load of 5,000 pounds (22.2 kN). Seat boards must be capable of supporting a live load of 300 pounds

(136 kg); 1910.27(b)(2)(vii)

Prompt rescue of each employee is provided in the event of a fall; 1910.27(b)(2)(viii)

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The ropes of each rope descent system are effectively padded or otherwise protected, where they can contact edges of the building, anchorage, obstructions, or other surfaces, to prevent them from being cut or weakened; 1910.27(b)(2)(ix)

Stabilization is provided at the specific work location when descents are greater than 130 feet (39.6 m); 1910.27(b)(2)(x)

No employee uses a rope descent system when hazardous weather conditions, such as storms or gusty or excessive wind, are present; 1910.27(b)(2)(xi)

Equipment, such as tools, squeegees, or buckets, is secured by a tool lanyard or similar method to prevent it from falling; and 1910.27(b)(2)(xii)

The ropes of each rope descent system are protected from exposure to open flames, hot work, corrosive chemicals, and other destructive conditions. 1910.27(b)(2)(xiii)

[81 FR 82990-82991, Nov. 18, 2016]

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 on the performance, inspection, use, and maintenance of these systems. Like OSHA's construction standards, the final rule prohibits the use of body belts as part of a personal fall arrest system;

Inspection of walking-working surfaces

Inspection of walking-working surfaces (§1910.22(d)). The final rule requires that employers inspect walking-working surfaces regularly and as needed and correct, repair, or guard against hazardous conditions; and

Training (§1910.30). The final rule adds requirements that employers ensure workers who use personal fall protection and work in other specified high hazard situations are trained, and retrained as necessary, about fall and equipment hazards, including fall protection systems. Employers must provide information and training to each worker in a manner the worker understands.

Evaluation of Locations

The manager or their designee will evaluate potential fall hazards and identify locations where protection against fall hazards using engineering or where the facility needs a fall arrest systems. 1910.132(d)(1), 1910.132(d)

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Managers or their designee will select fall protection equipment based on the hazard presented and compliance with the ANSI and OSHA standards for fall protection equipment (ANSI Z359.1-1992 or ANSI A10.14-1991). The marking on the manufacturer equipment tags typically indicate the applicable standard. 1910.132(d)(1)(i)

Unprotected Sides and Edges

Employees working or walking where there is an unprotected ledge, including hoisting areas, holes, ramps and walkways with a fall exposure of four feet or more, roofs with unprotected sides and a height of four feet or more to a lower level will be protected from falls by installation of a guardrail system or a personal

fall arrest system. 1910.23(a)(8)(i)

Guardrail Systems

A standard railing shall consist of top rail, intermediate rail, and posts, and shall have a vertical height of 42 inches nominal from upper surface of top rail to floor, platform, runway, or ramp level. The top rail shall be smooth-surfaced throughout the length of the railing. The intermediate rail shall be approximately halfway between the top rail and the floor, platform, runway, or ramp. The ends of the rails shall not overhang the terminal posts except where such overhang does not constitute a projection hazard. 1910.23(e)(1)

For pipe railings, posts and top and intermediate railings shall be at least 1 1/2 inches nominal diameter with posts spaced not more than 8 feet on centers. 1910.23(e)(3)(ii)

For structural steel railings, posts and top and intermediate rails shall be of 2-inch by 2-inch by 3/8-inch angles or other metal shapes of equivalent bending strength with posts spaced not more than 8 feet on centers. 1910.23(e)(3)(iii)

The anchoring of posts and framing of members for railings of all types shall be of such construction that the completed structure shall be capable of withstanding a load of at least 200 pounds applied in any direction at any point on the top rail. 1910.23(e)(3)(iv)

Toe Boards

A standard toeboard shall be 4 inches nominal in vertical height from its top edge to the level of the floor, platform, runway, or ramp. It shall be securely fastened in place and with not more than 1/4-inch clearance above floor level. It may be made of any substantial material either solid or with openings not over 1 inch in greatest dimension.

Where material is piled to such height that a standard toeboard does not provide protection, paneling from floor to intermediate rail, or to top rail shall be provided. 1910.23(e)(4)

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Floor Openings

Every floor hole into which persons can accidentally walk shall be guarded by either: 1910.23(a)(8)

A standard railing with standard toeboard on all exposed sides, or 1910.23(a)(8)(i)

A floor hole cover of standard strength and construction. While the cover is not in place, the floor hole shall be constantly attended by someone or shall be protected by a removable standard railing. 1910.23(a)(8)(ii)

Wall Openings 1910.23(b)(1)

Every wall opening from which there is a drop of more than 4 feet shall be guarded by one of the following:

Rail, roller, picket fence, half door, or equivalent barrier. Where there is exposure below to falling materials, a removable toe board or the equivalent shall also be provided. When the opening is not in use for handling materials, the guard shall be kept in position regardless of a door on the opening. In addition, a grab handle shall be

provided on each side of the opening with its center approximately 4 feet above floor level and of standard strength and mounting. 1910.23(b)(1)(i)

Extension platform onto which materials can be hoisted for handling,and which shall have side rails or equivalent guards of standard specifications. 1910.23(b)(1)(ii)

Every chute wall opening from which there is a drop of more than 4 feet shall be guarded by one or more of the barriers mentioned above. 1910.23(b)(2)

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Any employee required to work near openings that have a fall exposure of four feet or more to a lower level and the edge of the opening is less than 42 inches from the working surface; the opening will be guarded by a guardrail or a personal fall arrest system.

Bin, Silo, Tanks and Confined Spaces

When entering a bin, silo, tank or confined space from the top, the Facility Manager or their designee will provide fall protection equipment to employees such as a tripod and winch. Additional personal protective equipment may be required depending on the task involved when entering these environments refer to the Storage Structure Entry Program and/or Confined Space Program.

Forklift Hoisting of Personnel

This method of raising and lowering workers is acceptable under certain conditions.

The cage the employee would stand on or in will meet all of the guardrail standards for weight, railing and toe boards.

The cage will be properly attached to the forklift by devices such as locking pins or a secured chain.

The employee will be attached to the cage or forklift with an approved personal fall arrest system.

The employee in the basket will be equipped with a means of disconnecting the power to the lift and/or an employee will be present at all times who is in charge of controlling the lift.

Unstable objects shall not be used as working platforms.

Front-end loaders and similar pieces of equipment shall not be used to support scaffold platforms unless they have been specifically designed by the manufacturer for such use. 1926.451(c)(2)(iv)

Fork-lifts shall not be used to support scaffold platforms unless the entire platform is attached to the fork and the fork-lift is not moved horizontally while the platform is occupied. 1926.451(c)(2)(v)

The lifting of personnel via a forklift using a pallet is strictly forbidden

The basket or device will be kept at a minimum of 10 feet or greater from power lines.

Aerial Lifts

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When using aerial lifts such as scissor lifts and other lifts, follow manufactures operating manuals and procedures. The following are general guidelines to consider when using any aerial lift:

Employees using the aerial lift will have a harness and shock absorbing lanyard attached to an appropriate anchor point on the aerial lift. Inspect daily before use - oil levels, batteries, tires etc Run the lift through a range of motions prior to boarding Prior to moving a lift with employees in the enclosure, retract the platform to lower the center of gravity. Be aware of the operating surface area avoid uneven surfaces and obstructions. This will be accomplished by walking the area prior to moving the lift.

Be alert to any overhead obstructions such as electrical lines. The basket or device will be kept at a minimum of 10 feet or greater from power lines.

Always attach to the manufacturer’s designated anchorage point when in the lift basket or platform.

Fall Protection Systems

At a minimum, a permanent platform with standard guardrails or fall protection systems where railcars and trucks are positioned inside of or contiguous to a building or other structure will be provided. 1910.23(c)(1)

Where fall protection systems are in use, the facility will meet the following requirements:

Employees will use the fall protection equipment whenever they are on top of a railcar, regardless of the activity or purpose.

Where a permanent horizontal cable or beam fall protection system is available, employees will wear a full-body harness attached to a self-retracting lifeline.

A tag-line rope will be attached to the self-retracting lifeline and when an employee accesses the top of the railcar or truck, the rope can be pulled to the entry landing and allow the employee to hook up to the D-ring of the full-body harness prior to climbing on the top of the rail car. The use of the tag-line rope will minimize exposure of the self-retracting lifeline to elements and contamination.

Working Without Engineered Fall Protection

Where accessing the top of a railcar or truck positioned away from a building or other structure with no fall protection or guarding, the facility will implement the following protocols:

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Employees will maintain a 3-point contact with the ladder when climbing up or down. To get tools to the tops of the railcar or truck, employees will utilize rope to lift the tools. (If two employees are available, one employee can hand the tools up.)

Personal Fall Protection shall be utilized when work is performed at a height of four feet or more outside of fall protected and guarded control areas. OSHA memo October 18, 1996 regarding Enforcement of Fall Protection on Moving Stock.

Management does not permit employees to access the top of railcars without fall protection when icy and snowy conditions exist or when the sustained wind conditions exceed 20 miles per hour. Climbing during periods of inclement weather required approval from management so verification can be made as to the conditions of the climbing/walking/working surfaces and additional safety protocols (if any) can be implemented.

Railcars will have a posting (i.e., a derailer with a sign noting “Stop Men At Work” or “Stop Tank Car Connected”) to communicate that employees are on top of the rail car and prevent railcar movement.

The following requirements apply to work on top of a truck or railcar regardless of the situation:

This facility does not allow employees on top of a railcar during switching operations or other movement and does not allow employees on top of trucks while they are in motion.

If a control vehicle is attached to rail cars (such as during loading operations) the control vehicle operator and the person opening or closing lids will be in communication so the operator knows when someone is on top of the rail car and to keep the brakes on and the control vehicle in neutral.

Opening Lids

Due to the dangers of working on top of railcars, employees should take the following precautions when opening lids:

If lids may be frozen, employees will take and utilize the necessary tools to break loose the lids so they can be opened without having to exert significant force. Tools may include a rubber mallet with long handle, pry bar, or other tools deemed necessary to complete the job safely.

Employees should utilize proper lifting techniques when opening lids. Bend at the knees with your back straight and use your legs to lift the lid.

If the door is tight, the employee will attempt to break the seal with a rubber mallet by gently striking the door at several locations or utilizing a pry bar at several locations. Care will be exercised not to damage the lid when trying to open it.

Personal Fall Protection Devices

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Full Body Harness

A full body harness will be used for fall protection. Do not use a belt-style harness for fall protection. 1926.502(d)

Follow the manufacturer’s instructions for the proper donning and adjustment of a full body harness. The typical donning and adjustment instructions are:

First, lay the harness out on a clean, flat surface to ensure there are no tangles or twists in the webbing and to make it easy to perform the pre-use inspection.

Place the shoulder straps on and secure all corresponding harness buckles. Adjust all straps and buckles so that the harness fits snuggly, but still allows free movement. The

correct fit occurs when the employee can place 4 fingers flat between the leg straps and leg. Ensure the sub-pelvic strap is positioned just below the buttocks and the chest strap is across

the center of the chest. The dorsal “D” ring should be positioned centrally between the shoulder blades. All the keepers should be positioned properly to prevent webbing slippage and entanglement. Straps should not be twisted. They should lay flat when in position on the body. Conduct a buddy check and attach the fall arrest connector to the Dorsal D-ring on the harness

to begin working.

Manufacturers make standard harnesses for users weighing less than 310 pounds and for those exceeding 310 pounds up to a maximum of 400 pounds. If the user’s total weight, including clothing and carried equipment, exceeds three hundred ten pounds, a 400 pound rated full body harness will be required to ensure the safety of the user. It is critical when ordering these harnesses that the correct weighed unit is purchased.

Connectors

Connectors couple parts of a fall arrest system, rescue system or positioning device system together.

Connectors include snap hooks, carabineers, lanyards and shock absorbers.

Allowing auto-locking snap hooks for fall protection that has a self-locking gate, which remains closed and locked until intentionally unlocked by the user and opened provides the most secure personal protection. 1926.502(d)(6)

When coupling snap hooks to an anchorage or D-ring use larger diameter hardware than the snap hook to prevent a forced rollout or false connection. A forced rollout may occur when a snap hook is attached in a manner that causes the side of the gate to be pried open. A false connection can occur

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when the user cannot see the attachment of the snap hook with the component. An example of that could be the attachment of a snap hook to a D-ring on the back of a harness. A buddy check can help eliminate the possibility of a false connection. 1926.502(d)(6)(iii)

Snap hooks will never be connected together to connect two lanyards for additional length (i.e., daisy chaining), because of the increased potential of forced rollout and additional freefall.

Carabineers are generally oval in shape with a gate on one side that may be opened to attach to a fall protection or rescue component. Most carabineers are designed to take the majority of the load along the section from the gate, rather than equally on both sides. Carabineers shall not be loaded across the gate or the opening device.

Lanyards are used as a connector between the anchorage and the body harness. Lanyards come in a variety of lengths and materials. The maximum length of the lanyard when used in a fall arrest system is 6 feet. The length of the lanyard is a very important consideration to minimize the freefall distance.

D-ring extenders for full body harnesses are permitted provided the facility follows the manufacturer’s recommendations. The employee needs to be reminded that this will increase the overall fall distance by 18 inches.

Do not tie knots in lanyards as this can reduce the lanyard strength by half.

Lanyards should be connected at or above the shoulder of the user to minimize the free fall distance.

Walking too far away from the anchorage point can create a swing fall hazard.

If a lanyard has been used to arrest a fall, management will determine if the lanyard can be sent for recertification of its ability to function as intended or if it shall be discarded.

Shock absorbers are used to dissipate energy and reduce the forces on the falling employee and the anchorage. Shock absorbers will retain the force of a fall below 900 pounds and will deploy or extend more than 3.5 feet.

The deployment or extension of a shock absorber will be added to calculations of total fall distance to ensure that the employee does not hit the ground or another obstruction. Employees will be aware that the maximum length of a lanyard used with a shock absorber is 6 feet and the deceleration device is 3.5 feet with a maximum length of 9.5 feet.

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Shock absorbers have a deployment label or extend in such a manner to visually display that they have been loaded or have arrested a fall. Once a shock absorber has been deployed take it out of service and destroy it before it can be reused.

Lifeline

A life line is utilized to keep in contact with an employee while performing certain tasks such as confined space entry. It is generally a Polyester sheath with polypropylene core with a snap hook or positive attachment to a full body harness being worn by the employee entering a horizontal confined space and

control is maintained by the attendant outside of the confined space. The life line will only be used for the “purpose intended” and will be inspected periodically to ensure it is acceptable to use. It will not be utilized for lifting or dragging of materials. 1926.502(d)(11)

Self-Retracting Lifelines 1926.502(d)(12)

Self-retracting lifelines contain a drum wound line. Under normal operation the line may be extracted and retracted under slight tension when the user moves vertically away from and towards the device. In the event of a fall, the device will quickly lock the drum and prevent the lifeline from paying out, thus arresting the users fall. The self-retracting lifelines will lockup. Self-retracting lifelines are equipped with a load

indicator, which visually shows if the it has been loaded or has arrested a fall. The indicator can be a colored band that appears on the connector, a colored window or button that pops out on the housing, or a rip-stitch indicator on the line. All self-retracting lifelines should be removed from service following the arrest of a fall, or if the load indicator is visible. Follow manufacturer’s instructions for inspection, care, maintenance, and recertification. Self-retracting lifelines and lanyards which automatically limit free fall distance to 2 feet (0.61 m) or less shall be capable of sustaining a minimum tensile load of 3,000 pounds (13.3 kN) applied to the device with the lifeline or lanyard in the fully extended position.

Self-retracting lifelines and lanyards which do not limit free fall distance to 2 feet (0.61 m) or less, ripstitch lanyards, and tearing and deforming lanyards shall be capable of sustaining a minimum tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeline or lanyard in the fully extended position. 1926.502(d)(13)

Important things to remember when using a Self-Retracting Lifelines:

They should always be positioned directly above the employee.

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They should not be used in granular surfaces because the slow sinking of a worker will not be fast enough to lock up the unit.

Never attach lanyards onto the lifeline to extend their length.

An 18-inch D-ring extension with a self-locking snap hook at the other end is acceptable for use on the D-Ring to extend coverage area.

Do not introduce any slack into the line by clamping, knotting or running the line over obstructions or around the body. In a fall, this slack may cause unnecessary freefall that could cause an overload to the system and cause it to fail.

A self-retracting lifeline will not be stored in an extended position.

A tag line should be used to retrieve the end.

If the self-retracting lifeline has been deployed the manufacturer will service it immediately.

Vertical Lifelines and Rope Grabs

A vertical lifeline is a vertically suspended flexible line with a connector at the upper end for fastening to an overhead anchorage. While the worker climbs or descends, the rope grab is either moved by the worker or follows the worker and will lock onto the line in the event of a fall.

A rope grab consists of any device, which travels on a lifeline and will automatically lock onto the lifeline in order to arrest the fall of the user. Rope grabs are categorized as either manual or automatic. Manual rope grabs

usually rely on the lever or cam lever principle to arrest a workers’ fall. They are designed to remain locked onto the lifeline until the worker disengages the locking mechanism manually. Automatic rope grabs are best used when hands-free operation is required. They may incorporate an inertia locking mechanism, which rely on speed of descent, rather than changing the angle of cam levers.

A horizontal lifeline is a cable or rope that is connected between two fixed anchorages at the same level.

While, a horizontal rigid rail is a beam or track parallel to the ground that is supported by two or multiple points along its path. Both of these systems are designed, engineered and installed to provide horizontal movement and protection of employees while working under this fall protection device. All fixed fall protection systems will be designed by a professional engineer and installed by competent persons.

Records will be maintained by facility management to verify this requirement.

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Horizontal systems allow attachment of other connectors for fall arrest or fall restraint protection. One connector may be a SRL. A trolley will provide mobility for the self-retracting lifeline attachment to worker and ensure that it is positioned directly above the worker to minimize swing fall. A self-retracting lifeline can be used if the worker is also required to move up and down as well as along the length of the system such as a rail car or tanker car. When a self-retracting lifeline on a trolley system is not in use, the cable should be stored in its fully retracted position to enable an employee easy access and use without placing them in an unsafe situation. A platform will be provided for the employee to access the area. When the employee is on the platform, the tag line to the self-retracting lifeline will be available for the employee to attach to prior to getting on top of rail cars or elevated equipment.

Horizontal lifelines are a very complex system of sub-components. The resulting forces on the end anchorages of a horizontal lifeline are much higher because the fall distance will be greater than expected for a conventional fall arrest system due to the additional sag from the lifeline. If a shock-absorbing lanyard is used, then it should be as short as possible to minimize free fall distance.

Regardless either system is engineered and designed for a certain number of employees. If unsure how many employees the system is designed for, contact your respective or the installer.

Rigid rail systems are primarily permanent in design and installation, and often more costly than horizontal lifelines. In most cases, a rail, beam or track is welded, bolted or clamped, to an existing structure or building. Horizontal rail systems do not sag like horizontal lifelines so there are fewer factors to consider. The span between supports, the strength of the existing structure, the type of construction of the rail, the number of workers, and the connection method will be considered. 1926.502(d)(8)

Anchorage Points

Proper selection of an anchorage points to tie-off is critical. These points have to be structurally sound and capable of supporting a static load of 5,000 pounds per person. 1926.502(d)(15)

Anchorage points will be approved by a Facility Manager or their designee and a competent person. 1926.502(d)(15)(ii)

“A competent person Qualified means one who, by possession of a recognized degree, certificate, or professional standing, or by extensive knowledge, training, and experience.

A standard hand rail is never an acceptable anchorage point because they are only designed to withstand an outward force of 200 pounds.

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Anchorage points that can be pre-planned shall be constructed and painted safety yellow or orange. At facilities which do not have anchorage points identified, management or their designee will assign an anchorage point for employee use as tasks warrant employees to be outside of guarded areas.

Carefully select the anchorage point to limit the free fall to a maximum 6 feet and reduce swing fall hazards (swinging and hitting an object or obstruction) and to avoid striking an object during a fall. An anchorage point that is directly above the worker will minimize freefall and swing fall.

Do not connect locking snap hooks to a structure if the lock cannot be closed.

Do not wrap lanyards around a structure and tie back to it. Instead, use a beam wrap specifically designed for this application. A sling will be used in such instances and the snap hook can be connected to the sling. The sling will be long enough to entirely encircle the anchorage with length to spare and the smaller connection fit through the larger ring for attachment.

Working Surfaces (platforms)

1910.29(g)(4)

Platforms used with fixed ladders provide a horizontal surface of at least 24 inches by 30 inches (61 cm by 76 cm).

Storage, Inspection and Maintenance 1910.132(a)

Facilities will store fall protection equipment in a cool, dry and clean environment out of direct sunlight and avoid areas where chemical vapors exist. Employees using fall protection equipment will return the equipment to the designated storage area, unless they have been assigned your own equipment (i.e. full-body harness). Most manufacturers require fall protection equipment undergo a periodic inspection by competent persons. Maintain the records of these inspections for the user life of the equipment.

The user is required to inspect the equipment before each use.

Facilities will comply with the manufacturer’s “User Life” spans for equipment such as full body harnesses. Equipment will be taken out of service and destroyed when its user life span has expired.

User Responsibilities

Before each use of the equipment (full body harness, lanyards etc.), it will be carefully inspected by the user to assure that it is in a safety and serviceable condition. 1926.502(d)(21)

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Check for worn or damaged parts, inspect the stitching, ensure all hardware (i.e. self-locking snap-hooks, thimbles, D-rings, buckles etc) are present and secure and are not distorted, or have any sharp edges, burrs, cracks or corrosion.

Make sure locking snap hooks and carabineers function properly.

Inspect rope or webbing for wears, cuts, burns, frayed edges, breaks or other damage. Do not use the equipment if an inspection reveals any unsafe condition or a missing or illegible tag.

If any of these conditions exist, inform management and tag the equipment and remove it from service

The user will store this equipment in the designated storage areas and out of the sunlight to prevent damage.

If the user experiences a fall, they will immediately notify the Facility Manager or their designee immediately, remove this affected equipment from service, tag the equipment “Do Not Use” and destroy the equipment or send equipment for recertification if available.

The user will clean the harness, lanyards etc, with water and a mild soap detergent solution, wipe off the hardware with a clean, dry cloth and hang to air dry (i.e., not force dry with heat). An excessive build-up of dirt, paint, etc. may prevent equipment from functioning properly, and in severe cases degrade the webbing/rope to a point where it has become weakened and should be removed from service. If an employee has questions concerning the condition of equipment or doubts about putting it into service they should contact the Facility Manager or their designee.

Facility Responsibilities

The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment. 1910.132(d)(2)

Communicate selection decisions to each affected employee. 1910.132(d)(1)(ii)

Select PPE that properly fits each affected employee. 1910.132(d)(1)(iii)

Inspect harnesses, lanyards, anchorage connectors and life lines will be inspected once every three months and documented (initial tag attached to the item which is provided by the manufacturer.

Inspect self-retracting life lines by someone other than the user, preferably a member of management.

Service winches and recertify annually. Management will send in the winch annually to the manufacturer.

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Inspect winches and tripods monthly.

If a self-retracting life-line, full-body harness, rail car fall protection or any other fall protection equipment experiences a fall, immediately removed from service and tag it out.

If the fixed rail car fall protection experiences a fall, take it out of service. The vendor who inspects this equipment annually can work with site management to reinstate the rail car fall protection through digital photographs. It will be incumbent upon the manager to forward digital photographs to the vendor for review and evaluation as to whether or not to remove the equipment from service.

In the event an employee falls, or some other related, serious incident occurs, (e.g., a near miss) the employer shall investigate the circumstances of the fall or other incident to determine if the fall protection plan needs to be changed (e.g. new practices, procedures, or training) and shall implement those changes to prevent similar types of falls or incidents. 1926.502(k)(10)

Contractors

Contractors will be informed of this Fall Protection program when they are expected to perform work from heights of four feet or more. When contractors perform work that involves fall protection systems, management will:

Inform the contractor about this Fall Protection program specifically the precautions implemented in contractor work area.

Require the contractor to follow at least the minimum standards set forth in this Fall Protection program.

Require Contractors to be responsible for obtaining and using their own regulatory compliant Personal Protective Equipment.

Coordinate operations when the contractor(s) and facility employees are working on or near the same fall protection systems.

Rescue Plan

Where a facility uses personal fall arrest systems, the facility needs to able to be promptly rescue the employee should a fall occur. Management will attempt to minimize the suspension time so an employee is not suspended by a full body harness for more than 15 minutes since the onset of paralysis and decreased blood flow can occur. The facility should evaluate specific situations where employees use fall protection and how the facility can rescue an employee if a fall occurs and the employee is suspended. An alternative to a prompt rescue is to provide employee’s harnesses with a “Rescue Relief Device” which allows the employee to deploy foot holds or straps and relieve the pressure of the harness.

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Options for rescuing a fallen employee vary depending upon the situation. If the employee is conscious, use a ladder to permit the employee to either ascend of descend the ladder to safety. If the employee is unconscious, the local emergency services could be utilized by calling 911. Verification that the local emergency personnel are capable of providing rescue services in a timely fashion in all locations of the facility is necessary.

How To Comply With This Fall Protection Program:

Evaluate the need for fall protection and install where required Obtain the necessary fall protection equipment needed at the facility Perform and document the necessary periodic inspections on fall protection equipment Train applicable employees and document training for fall protection equipment Inform applicable contractors on the requirements of the fall protection program and document The Facility Manager or their designee will review this program annually and if they identify the

need for additional fall protection measures.

Training

The employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards. 1926.503(a)(1)

The employer shall assure that each employee has been trained, as necessary, by a competent person qualified in the following areas: 1926.503(a)(2)

The nature of fall hazards in the work area; 1926.503(a)(2)(i) The correct procedures for erecting, maintaining, disassembling, and inspecting the fall

protection systems to be used; 1926.503(a)(2)(ii) The use and operation of guardrail systems, personal fall arrest systems, safety net systems,

warning line systems, safety monitoring systems, controlled access zones, and other protection to be used; 1926.503(a)(2)(iii)

The role of each employee in the safety monitoring system when this system is used; 1926.503(a)(2)(iv)

The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs; 1926.503(a)(2)(v)

The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection; and 1926.503(a)(2)(vi)

The role of employees in fall protection plans. 1926.503(a)(2)(vii)

The employer shall provide training to each employee who is required by this section to use Personal Fall Protection Equipment. Each such employee shall be trained to know at least the following:

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When PPE is necessary; 1910.132(f)(1)(i) What PPE is necessary; 1910.132(f)(1)(ii) How to properly don, doff, adjust, and wear PPE; 1910.132(f)(1)(iii) The limitations of the PPE; and, 1910.132(f)(1)(iv) The proper care, maintenance, useful life and disposal of the PPE. 1910.132(f)(1)(v)

Each affected employee shall demonstrate an understanding of the training, and the ability to use Personal Fall Protection Equipment properly, before being allowed to perform work requiring the use of Personal Fall Protection Equipment. 1910.132(f)(2)

Certification of training.

The employer shall verify compliance by preparing a written certification record. The written certification record shall contain the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer. If the employer relies on training conducted by another employer or completed prior to the effective date of this section, the certification record shall indicate the date the employer determined the prior training was adequate rather than the date of actual training. 1926.503(b)(1)

It is good practice for employers to retain all personnel training documentation. The latest training certification shall be maintained. 1926.503(b)(2)

"Retraining." When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (a) of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where: 1926.503(c)

Changes in the workplace render previous training obsolete; or 1926.503(c)(1) Changes in the types of fall protection systems or equipment to be used render previous

training obsolete; or 1926.503(c)(2) Inadequacies in an affected employee's knowledge or use of fall protection systems or

equipment indicate that the employee has not retained the requisite understanding or skill. 1926.503(c)(3)

Note: The following appendices to subpart M of this part serve as non-mandatory guidelines to assist employers in complying with the appropriate requirements of subpart M of this part.

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Documentation Required

Daily: Inspect Walking and Working Surfaces (on Weekly Housekeeping Inspection. Monthly: Inspect Winches and Tripods (or as required by manufacturer) Quarterly:

Documented inspections of Personal Fall Protection (or as required by manufacturer.) Annually:

Training competency tests and certification of employees. Required Certification of Equipment

As Needed: Fall/Near Miss Investigations Area Hazard Assessments

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Understanding W&W Final Rule

Walking and Working Surfaces Final Rule

How Does It Affect My Grain Handling Facility?

On November 17, 2016, the final rule for walking and working surfaces became law and went into effect sixty days later, on January 17, 2017. This rule includes a graduated scale for implementation. Specifically, it includes the following changes on the dates shown:

1. Ensuring exposed workers are trained on fall hazards (6 months), May 17, 2017

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2. Ensuring workers who use equipment covered by the final rule are trained (6 months), May 17, 2017

3. Inspecting and certifying permanent anchorages for rope descent systems (1 year), November 17, 2017

4. Installing 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 (2 years), November 17, 2018

5. Ensuring 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 (2 years) November 17, 2018

6. Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet (20 years) November 17, 2036

You will note that only item number five of the dates does not affect the grain handling industry. How will items numbered 1 and 2 affect our industry? Training is required to be completed on at least an annual basis for hazardous tasks our workers are exposed to per regulation 1910.272(e). To be in compliance with item #1 we must ensure workers who use personal fall protection and work in other specified high hazard situations are trained by May 17, 2017, and retrained as necessary, about fall and equipment hazards, including fall protection systems. A qualified person must train these workers to correctly:

identify and minimize fall hazards; use personal fall protection systems and rope descent systems; and, maintain, inspect, and store equipment or systems used for fall protection.

How will item number 3 affect our industry? If your facility has a Rope Descent Systems (RDS), which consist of a roof anchorage, support rope, descent device, carabiners or shackles, and a chair or seatboard. Although these systems are widely used throughout the country to perform elevated work, most grain handling facilities do not have a RDS. But if your facility does have a RDS you will be required to have the anchorages inspected and certified no later than November 17, 2017. How will items number 4 and 6 affect our industry? These are the changes which will greatly affect the grain handling industry. If you have a ladder which has a total climbing distance in excess of 24 feet (a ladder is the distance from where climbing starts to where it ends rest platforms and offsets do not decrease the climbing distance.) Several years ago there was a change made to the walking and working surfaces regulation which decreased the distance a

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person could climb without a rest platform and offset ladder to 30 feet from 50 feet. This new regulation rolls back the distance for new or repaired ladder sections after 2 years and requires replacement after 20 years. The exception is the use of cages, the new regulation requires the use of climbing assistance devices in place of cages. This was designed to give employers more “flexibility” in their ability to protect their workers from fall hazards with fall protection tools used in the construction industry. The Fixed Ladder Regulations are as follows: https://www.osha.gov/walking-working-surfaces/RegTextWWSFinalRule.pdf Who is qualified to certify the anchorage points? In the final rule, “qualified” describes 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 relating to the subject matter, the work, or the project. What is a prompt rescue? Prolonged suspension from fall arrest systems can cause orthostatic intolerance, which, in turn, can result in serious physical injury, or potentially, death. Research indicates that suspension in a fall arrest device can result in unconsciousness, followed by death, in less than 30 minutes (SHIB 03-24-2004). In sum, prompt rescue means employers must be able to rescue suspended workers quickly enough to ensure the rescue is successful, i.e., quickly enough to ensure that the employee does not suffer physical injury (such as injury or unconsciousness from orthostatic intolerance) or death. What type of repair will require me to replace the cage with a ladder safety device? Final paragraph (b)(9)(i)(C) does not require that employers install ladder safety or personal fall arrest systems when they make minor repairs to fixed ladders, cages, or wells, such as replacing a bolt or repairing a weld on a cage. However, when employers determine that they cannot simply make a repair to a section or a portion of a section of a fixed ladder, cage, or well but must replace that portion or section, employers must ensure the replacement is equipped with a ladder safety or personal fall arrest system. OSHA believes the inspection requirement in final § 1910.22(d) will help employers identify when simple repairs or corrections will be adequate and when the situation, such as a condition that affects the structural integrity of the fixed ladder, cage, or well, necessitates replacement of the fixed

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ladder, cage, or well section. OSHA also notes that when “a portion of a section” of a fixed ladder, cage, or well needs replacement, the final rule only requires the employer to install a ladder safety or personal fall arrest system in that “section of the fixed ladder, cage, or well where the replacement is located.” The final rule does not require employers to install a ladder safety or personal fall arrest system on the entire fixed ladder when a portion of one section needs replacement. For example, only part of a 50-foot section of a cage, well or multi-section ladder might need replacement because of damage. Final paragraph (b)(9)(i)(C) only requires that the employer replace that 50-foot section of the ladder, cage, or well with a ladder safety system or personal fall arrest system, not all sections. OSHA believes that a “section” of a fixed ladder equipped with a cage or well most likely will not exceed 50 feet. In this regard, ladder sections are the length of ladder between landings or platforms, and final paragraph (b)(9)(iii) requires that fixed ladders that have cages or wells must have landing platforms at least every 50 feet. Again, this provision does not prohibit employers from keeping those portions of a cage or well that are functioning properly, or installing a new cage or well, provided the employer also installs a personal fall arrest or ladder safety system as final paragraph (b)(9)(i)(B) requires, and the cage or well does not interfere with the fall protection system. Since I no longer need a cages and rest platforms, what are requirements for one section fixed ladder? Final paragraph (b)(9)(ii) adds new requirements for one-section fixed ladders that are equipped with personal fall arrest systems or ladder safety systems and fixed ladders equipped with those systems on more than one ladder section. For these ladders, the final rule requires that employers ensure:

The personal fall arrest or ladder safety system provides protection throughout the entire vertical distance of the ladder, including all ladder sections (final paragraph (b)(9)(ii)(A)); and

The ladder has rest platforms provided at least every 150 feet (final paragraph (b)(9)(ii)(B)).

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Frequently Asked Questions

Agricultural Operations Why does the final rule exclude agricultural operations? Although OSHA believes that walking-working surfaces hazards, particularly fall hazards, are present in agricultural operations, the Agency did not propose to cover agricultural operations and did not gather and analyze the type of information necessary to support including agricultural operations in the final rule. In addition, because the proposed rule did not cover agricultural operations, the public, and in particular agricultural stakeholders, did not have an opportunity to comment on any protective measures OSHA might require.

What are agricultural operations? Although the final rule does not define agricultural operations, in the past OSHA has said they include:

Activities involved in growing and harvesting (including field sorting) of crops, plants, vines, fruit

and nut trees, ornamental plants, egg production, and raising livestock, poultry, fish and

livestock products (e.g., feed for livestock on the farm); and

Preparation of the ground, sowing, watering and feeding of plants, weeding, spraying,

harvesting, raising livestock, and all activity necessary for these activities .

In addition, activities integrally related to these core agricultural activities (e.g., delivery of feed to chickens) also are considered agricultural operations. Determining whether an activity is a core agricultural operation is made on a case-by-case basis based on the nature and character of the specific activity.

What activities are not core agricultural operations and, therefore, not excluded from the final rule? Post-harvesting activities are not integrally related to core agricultural operations; therefore, they are considered general industry activities that the final rule covers. These general industry post-harvesting activities include:

Post-harvesting activities not on a farm, such as receiving, sorting, cleaning, sorting, sizing,

weighing, inspecting, stacking, packaging and shipping; and

Processing of agricultural products that change the character of the product (e.g., canning,

making sauces) or involve a higher degree of packaging in a shed or other location (instead of

field sorting).

Also, activities performed on a farm that "are not related to farming operations and are not necessary to gain economic value from products produced on the farm" are general industry activities the final rule covers. These activities include:

Grain handling operations that store and sell grain grown on other farms;

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Grain milling facilities and the use of milled flour to make baked goods; and

Food processing facilities and manufacturing operations, such as making cider from apples

grown on the farm and processing large carrots into "baby carrots."