4.1 Walking-Working Surfaces & Housekeeping (29 CFR 1910.22)

4.1 Walking-Working Surfaces & Housekeeping (29 CFR 1910.22)

Introduction to Walking-Working Surfaces

Subpart D of 29 CFR 1910 governs walking-working surfaces in general industry. Walking-working surfaces include any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area. Bureau of Labor Statistics (BLS) data shows slips, trips, and falls cause approximately 15% of all accidental deaths in general industry. Consequently, OSHA's standards under 1910.22 are strictly enforced to eliminate physical hazards and promote safety.

General Housekeeping Requirements (29 CFR 1910.22(a))

Housekeeping is the foundation of any effective safety program. OSHA standard 29 CFR 1910.22(a) establishes three key rules:

1. Clean, Orderly, and Sanitary Work Conditions (1910.22(a)(1)): All places of employment, passageways, storerooms, and walking-working surfaces must be kept in a clean, orderly, and sanitary condition.
2. Dry Floors and Drainage (1910.22(a)(2)): The floor of each workroom must be maintained in a clean and, to the extent feasible, dry condition. When wet processes are used, drainage must be maintained, and dry standing places, platforms, mats, or appropriate waterproof footgear must be provided.
3. Free from Hazards (1910.22(a)(3)): Walking-working surfaces must be maintained free of hazards such as sharp objects, loose boards, corrosion, leaks, spills, snow, and ice.

Inspection and Maintenance of Surfaces (29 CFR 1910.22(d))

OSHA requires employers to inspect walking-working surfaces regularly and maintain them in a safe condition. Under 1910.22(d):

• Regular Inspections: Walking-working surfaces must be inspected regularly and as necessary to identify hazards.
• Immediate Repairs: Any hazardous condition must be corrected or repaired before employees are permitted to use the surface again.
• Guarding Interim Hazards: If the correction or repair cannot be completed immediately, the employer must guard or shield the hazard to prevent employees from using the walking-working surface until it is repaired or replaced. For example, if a hole in a concrete floor is discovered, it must be barricaded off or covered with a secured load-rated plate.

Floor Holes and Openings: Guarding and Cover Requirements

A critical aspect of walking-working surface safety is guarding holes and openings to prevent workers or materials from falling through them. OSHA makes a clear distinction based on size, although both require protection:

• Definitions:
  • A floor hole is an opening measuring less than 12 inches but more than 1 inch in its least dimension, in any floor, platform, pavement, or yard (e.g., a pipe opening).
  • A floor opening is an opening measuring 12 inches or more in its least dimension (e.g., a stairwell opening, hatchway, or chute).
• Guarding Methods: Under 29 CFR 1910.28, floor holes and openings must be protected by a standard guardrail system, a cover capable of supporting the required load, or a personal fall arrest system (PFAS).
• Cover Technical Standards (29 CFR 1910.29(e)): If a cover is used, it must be:
  • Capable of supporting, without failure, at least twice the maximum intended load of employees, equipment, and materials that may be imposed on it at any one time (known as the 2x safety factor).
  • Secured to prevent accidental displacement by wind, equipment, or employees.
  • Color-coded or marked with the word 'HOLE' or 'COVER' to provide warning of the hazard.

Floor Load Ratings (29 CFR 1910.22(b))

Overloading building floors is a major structural hazard that can lead to catastrophic collapse. To prevent this:

• Load Limit Determination: In all buildings used for mercantile, business, industrial, or storage purposes, the approved floor load limits must be determined by a registered professional engineer or building official.
• Marking and Posting: These load limits must be marked on plates and conspicuously posted in a clear, visible location to which they relate. These are typically called floor load rating plates.
• Compliance: It is a direct violation of OSHA standards to place, or cause to be placed, a load on any floor or roof of a building that exceeds the approved limit.

Dockboard and Dock Plate Safety (29 CFR 1910.30(a))

Dockboards (or dock plates) bridge the gap between a loading dock and a transport vehicle. Because of the heavy loads that cross them, safety requirements are stringent:

• Load Capacity: Dockboards must be strong enough to carry the load imposed on them. They must support the combined weight of the material handling equipment, the operator, and the load.
• Securing Mechanisms: Portable dockboards must be secured in position. This can be achieved by anchoring them or equipping them with devices that prevent them from slipping or moving out of safe position during loading or unloading.
• Safe Handling: Portable dockboards must be equipped with handholds to permit safe handling and prevent hand-pinch injuries.
• Slip Resistance: The surface of the dockboard must be slip-resistant (e.g., diamond plate steel or applied non-slip coatings).
• Trailer Restraints: Before a forklift enters a trailer, the trailer wheels must be chocked or secured using mechanical vehicle restraints (such as a dock lock) to prevent trailer creep.

Adherence to these housekeeping, inspection, and equipment guidelines reduces slips, trips, and falls.