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OSHA Subpart D paper


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									Running head: WALKING AND WORKING SURFACES                               1

                 Walking and Working Surfaces: 29 CFR 1910 - Subpart D

                         Physical Hazards Control – OSHT 1309

                          Professor Alfred “Freddy” Sustaita Jr.

                                      Sonia Webb

                                     March 27, 2011
WALKING AND WORKING SURFACES                                                                        2


       Each year thousands of workers are injured as a result of hazards associated with the

walking and working surfaces at their jobsite. Hazards associated with the surfaces include slip,

trips, and falls, struck by or crushed by, and lacerations. To address these issues, the

Occupational Safety and Health Administration developed 29 CFR 1910 Subpart D. This

regulation establishes the regulatory requirements for employers to take the appropriate measures

to control these hazards. Employers that comply with 29 CFR 1910 Subpart D have the

opportunity to reduce the number of accidents and the associated cost.
WALKING AND WORKING SURFACES                                                                         3

                        Walking and Working Surfaces: 29 CFR 1910 Subpart D

       Many employers do not realize, or choose to ignore, the potential hazards related to the

walking and working surfaces utilized by their employees. These workers are exposed to

tremendous dangers each day from hazards located on worksite floors, ladders, stairways, and

scaffolding. Surfaces that are not properly maintained or designed can result in employees

slipping, falling, or even possibly being struck by or crushed by materials or equipment. Injuries

such as slips, trips, and falls are the “leading cause of work-related injury,” injuring more than

200,000 employees each year (Kilbourne, 2010, para. 1). Many of the injuries resulting from

these incidents are minor; however, ninety-five percent of major fall incidents result in broken

bones (Von Hoegen, 2005, para. 2). Other common injuries associated with these hazards

include bruises, sprains, lacerations, and head or neck trauma all of which can possibly result in

days away from work (J. Cohen, LaRue, & H. Cohen, 2009, p. 27). Injuries resulting from slips,

trips, and falls during 2000 resulted in an estimated cost of $26.9 billion, and cost are expected to

reach as high as $32.4 billion by the year 2020 (J. Cohen, LaRue, & H. Cohen, 2009, p. 27).

According to the U.S. Bureau of Labor Statistics, fall incidents were also second only to highway

incidents as the leading cause of fatalities in 2009 (2010, p. 4). Information provided by the

Occupational Safety and Health Administration (OSHA) expresses that the majority of these

employees are injured or killed because they have not been protected from hazards or are not

utilizing protection methods correctly (Kilbourne, 2010, para. 3). No worksite is without walking

and working surfaces and every employer must take the appropriate measures to protect and

educate their employees. In order to ensure these measures to protect employees are taken,

OSHA developed 29 CFR 1910, Subpart D, which requires employers to provide employees

with clean and safe walking and working surfaces at all times. This paper will discuss the
WALKING AND WORKING SURFACES                                                                      4

significant regulatory requirements of Subpart D, the potential hazards and typical areas where

they are found, and the recommended methods for avoiding exposure to the hazards.

       The regulation 29 CFR 1910, Subpart D applies to walking and working surfaces and

includes regulatory requirements regarding housekeeping, floor and wall openings, stairways,

ladders, scaffolding, and manually propelled mobile ladder stands and scaffolds. The

requirements specified apply to “all permanent places of employment, except where domestic,

mining, or agricultural work only is performed” (Occupational Safety and Health Administration

[OSHA], 1996). Conditions set forth for housekeeping require employers to ensure walking and

working surfaces are “kept clean, sanitary, and free of any obstacles that will interfere with

equipment operation” (OSHA, 1996). The regulation specifies that this includes “all places of

employment, passageways, storerooms, and service rooms” (OSHA, 1996). Floor openings

which measure twelve inches or more in any direction require standard railing systems that guard

all exposed sides (OSHA, 1996). These openings also require a toeboard on all exposed sides

and a hinged opening cover when specified (OSHA, 1996). Wall openings are defined as an

opening which is at least thirty inches high and eighteen inches wide; however, the regulation

only applies when there is more than a four-foot drop from the opening to the level below

(OSHA, 1996). OSHA stipulates that qualifying wall openings must be guarded utilizing a “rail,

roller, picket fence, half door, or [an] equivalent barrier” and a removable toeboard when there is

a danger of material falling (1996). A guarding system and toeboard are also required when any

opening or exposed edge is located above “dangerous equipment, pickling or galvanizing tanks,

degreasing units, and similar hazards” regardless of the height (OSHA, 1996). According to

OSHA, a standard railing system shall have a vertical height of forty-two inches from the top

surface to the bottom surface, and consists of a top rail, intermediate rail, and post (1996).
WALKING AND WORKING SURFACES                                                                         5

Standard railing systems for stairs are required to be constructed in the same manner, except the

vertical height requirement is no more than thirty-four inches or less than thirty inches from the

upper surface of the top rail to the tread line of the stairs (OSHA, 1996). Fixed stairways that

have more than four risers must be equipped with standard stair railings or handrails as specified

and be clear of any obstructions. (OSHA, 1996).The regulation also specifies the design of the

stairway including the required strength, width, angle of rise, and tread (OSHA, 1996). Both

portable wood and metal ladders are covered by this regulation. Specific requirements are

provided to the employer regarding the design, use, inspection, and expected condition of both

types of ladder (OSHA, 1996). For example, portable wood ladders must have a minimum step

spacing no more than twelve inches, have a minimum width of eleven and one-half inches, and

be no longer than thirty feet for single ladders (OSHA, 1996). Fixed ladders must be designed to

meet load requirements and have sixteen-inch rungs or cleats that have no more than a twelve-

inch spacing (OSHA, 1996). Regulatory requirements pertaining to scaffolding are the most

extensive in 29 CFR 1910 Subpart D. The main requirements are that the proper equipment be

used with capabilities to support four-times the intended load without compromising the stability

of the structure (OSHA, 1996). Scaffolds shall be constructed with adequate materials, include

handrails and toeboards, and have safe access points (OSHA, 1996). Manually propelled mobile

ladder stands or scaffolds must be adequately designed for the conditions of use and have a

minimum handrail height of twenty-nine inches (OSHA, 1996). The regulatory requirements for

walking and working surfaces are extensive; however, many possible hazards can be avoided by

complying with the regulations.

       Employers that do not abide by the regulations established by 29 CFR 1910 regarding

walking and working surfaces expose their employees to numerous hazards including slip, trip,
WALKING AND WORKING SURFACES                                                                           6

or fall hazards, struck by or crushed by hazards, and lacerations. The most prevalent risk faced

by employees is the potential for a slip, trip, or fall incident (Von Hoegen, 2005, para. 1). These

types of dangers are present throughout the majority of worksites. Poor housekeeping practices

can create serious problems for employees. Items such as boxes or other debris not properly

stored or placed can potentially cause employees to trip or fall. Cables that are near or cross

pedestrian walking areas can also pose a trip or fall threat to employees if they are not properly

guarded or secured (Healthy Working Lives, n.d., para. 2). Floors with water or fluid, uneven

surfaces, or improper floor coverings present hazards which could lead to serious injuries

(Healthy Working Lives, n.d., para. 2). Unguarded floor and wall openings are dangerous

leaving employees exposed to fall hazards when performing job duties nearby. There are also

serious slip, trip, and fall hazards present on temporary and fixed stairways that do not have the

proper design, guarding, or handrails (J. Cohen, LaRue, & H. Cohen, 2009, p. 27). Ladders are a

tremendous threat to employees when they are not maintained or used properly. For example,

employees who rush and climb ladders too quickly are more likely to have a fall incident than

those who take a slower pace and climb the ladder more carefully (W. Chan & C. Chang, 2005,

p. 30). During the year 2009, falling from a ladder was the leading cause of death resulting from

a fall causing twenty percent of the total fatalities (U.S. Bureau of Labor Statistics, 2009, p. 7).

Elevated surfaces such as scaffolding also expose employees to fall hazards when they are not

properly designed for the purpose or adequately assembled. Although slips, trips, and falls are

the most prevalent walking and working surface hazard, the risk of being struck by or crushed by

materials or equipment is just as dangerous. The occurrence of an employee being struck by or

crushed by operators who are unable to see is increased when there are poor housekeeping

practices or design flaws in the layout of the work area. Lacerations are another danger which
WALKING AND WORKING SURFACES                                                                        7

may occur at worksites that have stairs, ladders, or scaffolding that are not well maintained and

have jagged or sharp edges. These injuries may also occur as a secondary injury to incidents

resulting from walking and working surfaces. Employees are exposed to many hazards as a

result of their employer not complying with OSHA standards; however, many of these can be

easily avoided or eliminated by abiding by the requirements of 29 CFR 1910 Subpart D.

       Although it is virtually impossible to eliminate every hazard from a worksite, following

the standards set forth by OSHA will greatly reduces the severity of hazards present. One of the

main tools in hazard reduction or elimination is the ability to recognize and assess potential risks

and establish adequate safety practices to eliminate those risks (Healthy Working Lives, n.d.,

para. 9). Simple housekeeping practices can reduce or eliminate the majority of worksite

hazards. For example, slips, trips, and falls are the “number one preventable” exposure at a

jobsite (Di Pilla & Vidal, 2002, p. 1). These risks can be easily addressed by keeping floor

surfaces clean, dry, in good condition or utilizing the adequate slip resistant materials when

necessary (Healthy Working Lives, n.d., para. 10). Equipment and materials stored properly,

cable placement or guarding, and signage are also easy housekeeping tactics to prevent walking

and working surface hazards (Healthy Working Lives, n.d., para. 11). Employers can prevent or

reduce many struck by or crushed by hazards by verifying that operators have adequate clearance

and no visual obstructions when operating materials handling equipment (OSHA, 1996). Areas

where this type of equipment is utilized must also have sufficient lighting to prevent injury

(OSHA, 1996). Many laceration hazards can be avoided by maintaining the worksite. For

instance, repairing wood handrails immediately will prevent employees from injuring hands or

other body parts. Materials or equipment with sharp edges should also be stored properly to

prevent contact with employees working nearby. The continuous training of employees to raise
WALKING AND WORKING SURFACES                                                                       8

employee awareness will also greatly reduce the potential for injuries. Employees must be

trained to use tools and equipment correctly as well as to recognize a potential hazard and take

preventative action. Inadequately trained employees are a key contributor to hazards on walking

and working surfaces. This was illustrated in the article “Portable Ladders: Understanding and

Preventing Slips at Their Bases” (Chang W. & Change C., 2005, p. 26). This article referenced a

study that exhibited that forty-five percent of the ladder accidents analyzed were caused by

improper ladder placement (Chang W. & Chang C., 2005, p. 26). Straight ladders were involved

in the majority of the accidents and the most common cause was the ladder slipping at the base

as a consequence of incorrect angling or being placed in areas with contaminants on the floor

(Chang W. & Chang C., 2005, p. 26). Many of these accidents were a direct result of employees

not receiving proper training on the use of ladders which would have potentially prevented half

the incidents (Chang W. & Chang C., 2005, p. 26). Employers who choose to protect their

employees by following the requirements set forth by OSHA can greatly reduce the number of

hazards and potential costs associated with walking and working surfaces.

       Each day employees across the nation are injured or killed as a result of walking and

working surface hazards. Though these hazards vary from those as simple as water on the floor

to more technical issues such as the poor design of scaffolding, each must be addressed and

eliminated. OSHA has established 29 CFR1910 Subpart D to provide employers with guidelines

to protect their employees from harm. By following these regulatory requirements as specified,

the majority of walking and working surface hazards can be drastically reduced or eliminated.

OSHA has provided the tools; however, it is the responsibility of the employer to utilize them to

protect the welfare of the men and women at their worksite.
WALKING AND WORKING SURFACES                                                                        9


Chang, W. & Chang, C., (2005, September). Portable ladders: Understanding and preventing

       slips at their bases. Professional Safety, 26-31. Retrieved from


Cohen, J., LaRue, C. & Cohen, H., (2009, January). Stairway falls: An ergonomics analysis of 80

       cases. Professional Safety. 27-32. Retrieved from http://www.asse.org/professionalsafety


Di Pilla, S. & Vidal, K., (2002, June). State of the art in slip-resistance measurement: A review

       of current standards and continuing development. Professional Safety. 37-42. Retrieved

       from http://www.asse.org/professionalsafety/pastissues/047/06/026353at.pdf

Healthy Working Lives, (n.d.) Slips, trips, and falls. Healthy Working Lives. Retrieved from


Kilbourne, C., (2010, December). Walking/working surface rules need changes, OSHA says.

       Safety Daily Advisor. Retrieved from http://safetydailyadvisor.blr.com/archive/


Occupational Safety and Health Administration, 29 C.F.R. pt. 1910 (1996). Retrieved from



U.S. Bureau of Labor Statistics, U.S. Department of Labor, (2009). Census of Fatal

       Occupational Injuries. Retrieved from http://www.bls.gov/iif/oshwc/cfoi/cfch0008.pdf

Von Hoegen, T., (2005, July). Slips, trips, and falls: The correct footwear will have a positive

       effect. Health & Safety International. Retrieved from http:hsimagazine.com/article.


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