Thoughts and perspectives from the team.

Are You In Compliance With OSHA’s New Walking-Working Surfaces and Fall Protection Regulations?

AUTHOR Keith Brossard


PUBLISHED May 8, 2018

In the realm of safety, slips, trips, and falls constitute the majority of general industry accidents. Of that, 20% of all disabling occupational injuries result from falls. These accidents happen for several different reasons, including loss of traction or balance.

During 2017, OSHA issued a final regulation for walking-working surfaces standards and establishing the requirement for establishing personal fall protection requirements.



OSHA Regulations Are Changing with Advances in Technology

OSHA’s new walking-working surface and fall protection rule is the first official update to a rule that hasn’t been updated since 1972. Old standards recognized the use of guardrails and barriers as primary methods of protection, but did not directly recognize personal fall protection systems.

With new technological advances in fall protection, the rule now provides flexibility for tank owners to choose the equipment and controls that work best for their company and the steel tank. When the OSHA Compliance Official visits your facility, it’s too late to find out that you should have updated the fixed ladders on your storage tanks with the proper fall protection.

Luckily, there is a phase in period for these changes to be made. A proactive attitude on implementation of these rules will make for an easy transition.


What Does the New Rule Say?

The new regulation states all new fixed ladders over 24 feet must be equipped with one of these solutions:

  • Cage

  • Well

  • Ladder safety system

  • Personal fall arrest system

All existing fixed ladder cages and wells over 24 feet must be in compliance by November 18, 2036. A fixed ladder includes individual rung ladders but not ship stairs, step bolts or manhole steps which have a separate set of regulations.

With the implementation of this rule, OSHA estimates that it will prevent 29 fatalities and 5,842 injuries annually.

When reading through the regulation, T BAILEY, INC. noted that these additional items might impact your company:

  • Training - All employees must be properly trained by a qualified person to ensuring employees can properly recognize and identify fall hazards, the procedures to minimize those hazards and the correct procedures for installing, inspecting, operating & maintaining personal fall protection systems.

  • Slide & Corrosion - Individual-rung ladders are to be constructed to prevent the employee’s feet from sliding off the ends of the rung. Additionally, metal ladders must be protected against corrosion or made with corrosion-resistant material.  

Whenever an older tank is being repaired or upgraded, T BAILEY, INC. works with the tank owner or engineer to ensure that OSHA upgrades be made at the same time, and helps you determine the best type of fall protection system for your company and the tank.

We offer climbing safety devices from several leading manufacturers to ensure you are in compliance, and can assist in training your staff to ensure you are using them properly.


Maintaining Compliance With OSHA Regulations

Most facilities send workers out alone to inspect or monitor their tanks. Make sure they are safe by updating your tanks with ladder safety climbing systems supplied by T BAILEY, INC. and ensuring your facility is in compliance with OSHA Regulations.

For further information please visit the Department of Labor OSHA site.

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