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January-February 2017

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palletcentral.com PalletCentral • January-February 2017 31 Other general requirements for walking/working surfaces include mandates to: • Keep WWS clean, orderly, sanitary. • Keep WWS free of hazards such as sharp or protruding objects, spills, snow and ice. • Ensure that the WWS will support maximum intended load. • Provide and ensure use of safe means of access and egress to/from each WWS. • Inspect WWS "regularly and as necessary" and maintain in safe condition. • Correct or repair hazardous conditions on WWS before workers use it again, or else guard the area to prevent use until the hazards are corrected, • Have a qualified person perform or supervise the correction/ repair, when a correction/repair involves the structural integrity of the WWS. The rule requires employers to protect workers from fall hazards along unprotected sides or edges that are at least 4 feet above a lower level, and also has specific requirements for both fixed and portable ladders, scaffolds, fixed and portable dockboards, and other equipment that presents a fall hazard. One issue that was somewhat controversial was whether OSHA would continue its exemption from the standard for "rolling stock" and motor vehicles (such as flatbed trucks and tractor-trailers). OSHA's definition of "walking-working surface" in the current construction rule does not include rolling stock and motor vehicles (1926.500(b)). For general industry, OSHA issued an interpretative letter in the 1980s indicating that it would not enforce the fall protection standards relative to this equipment. In the new final rule, OSHA states that it is feasible to provide fall protection for rolling stock, even when it is not contiguous or next to a structure, but it opted to exclude any specific requirements for fall protection for these vehicles. Therefore, existing enforcement policies remain in effect. However, it is still possible for OSHA to cite under the General Duty Clause, if the fall was a recognized hazard, and there was a feasible method of providing protection for the worker accessing the mobile equipment or rolling stock (such as a tie-off rack).

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