Walking And Working Surfaces Standard Adoption In California

In May, the California Department of Industrial Relations, Occupational Safety and Health Standards Board, drafted a notice of the intent to adopt the Federal Walking-Working Surfaces standard. The standard was released by Federal OSHA in January of 2017 but had not been addressed by California until now. There will be a public hearing on this adoption on June 21^st. You can get more details here.

The State of California has chosen to adopt these standards and make changes to their own standard wording in stages. The first stage will address the items below:

• Fixed and Portable Ladders
• Mobile Ladder Stands and Scaffolds
• Stairways
• Step Bolts and Manholes

Many of the requirements in these standards are already in place or are simply wording or organizational changes to older standards. There are, however, some new requirements. Although a total review is beyond the scope of this blog, I will outline two of the larger changes.

• Fixed ladder systems: Once a fixed ladder reaches 24 feet in height, the new standard requires tie off. No longer will cages around ladders meet the standard. New ladders meeting these parameters (24 feet or more) must include tie off, or as the standard puts it, “a ladder safety system”. This type of system is defined in the standard and is really tie off centric. Old ladders or sections of ladders meeting these parameters must be retrofitted if they are replaced. Lastly, 24-foot or taller ladders must all be retrofitted or changed out by November 18, 2036. Other requirements for ladder systems, such as maximum side step distances, are also in this standard. If you have these types of ladder systems you will want to read through this part of the standard wording.
• Walking-Working Surfaces. Another part of the standard bears examination at the outset. In 1910.22 (the Fed standard title), starting at the bottom of page 7, general requirements are outlined. Among these requirements, the standard now overtly states that employers are required to maintain walking and working surfaces “free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow, and ice.” It also now requires inspections and a number of other actions that were, prior to, expected, but there was not a specific standard to cite by. There is now a specific standard to cite which means OSHA will cite more often and to greater effect. If you choose to read the portion of the standard, note the requirements for dry floors and storage areas. In truth, this section is probably the most mundane section but may end up being the hardest part of the standard to comply with.

As additional topics roll out, they will be based on the other sections outlined in the Federal standard wording, such as requirements for fall protection systems 1910.140. You can look through these at the link provided. A perusal of the topic headings will give you a good idea of what the future holds. This also includes a new flat roof, infrequent work, 15-foot set-back, exception that may be interesting to you if you have a flat roof. It relaxes some of the Federal standards but does require specific things to be in place to take advantage of it.

Again, this topic has not yet been proposed for adoption by California OSHA but if the board decides to adopt the exception it could affect many building owners and provide some flexibility in the way they choose to comply.

Please feel free to contact me directly or your Woodruff Sawyer account team for more information on this topic.