WHITEPAPER
WALKING-WORKING SURFACES TRAINING:
PROTECTING WORKERS FROM FALL HAZARDS
Copyright 2021 J. J. Keller & Associates, Inc. All rights reserved.
50374
PROTECTING WORKERS FROM FALL HAZARDS
Training is one of the most critical elements in a safety and health management program.
Providing workers with the required skills and knowledge to safely perform their work
helps prevent injuries. Many OSHA standards contain specific training requirements,
including a number of provisions in 1910 Subpart D, Walking-Working Surfaces.
Not every employee will require training under Subpart D. However, any worker exposed
to fall hazards or using fall protection equipment will need training.
You may need to train
employees even if
a regulation doesn’t
explicitly mention
training
Training is an investment, and OSHA notes that effective training can:
• Change or modify unsafe behavior,
• Increase hazard recognition,
• Promote safe work practices, and
• Increase engagement in a company’s safety and health management program.
WALKING-WORKING SURFACES
TRAINING REQUIREMENTS
Employees must be able to recognize fall hazards to which they may be exposed, so
training must cover the specific fall hazards in each trainee’s work area. Employees also
need to understand the procedures they must follow to minimize those hazards, such as
procedures to install, set up, inspect, operate or use, maintain, disassemble, and/or store
the fall protection systems and equipment provided to them.
Note that you may need to provide training even if a regulation does not specifically
require it. For example, OSHA does not explicitly require training on how to inspect
ladders. However, OSHA does require workers to inspect ladders before the first use on
each shift. In order to properly inspect a ladder for defects, workers need training on
what to look for during those inspections.
Similarly, you should train employees to use ladders properly. Using a ladder may seem
simple, but OSHA has issued citations for things like using a stepladder in the folded
position by leaning it against a wall. Stepladders are designed to be used in the open
position, which keeps the feet properly on the ground and the steps level. Instructing
employees on the proper use of equipment, including ladders, helps avoid citations and
reduces injuries.
Section 1910.30, Training, outlines most of the training requirements. The performancebased requirements allow flexibility to tailor both the content and training methods to
your workplace. For example, that section notes that:
• If employees use dockboards, they need training on how to properly place them and
secure them.
• If employees use rope descent systems, they need training on proper rigging and use.
Employers must fill in the details for the particular equipment used, applying industry best
practices and using guidance from the equipment manufacturer.
WALKING-WORKING SURFACES TRAINING:: PROTECTING WORKERS FROM FALL HAZARDS
2
Fall protection training
The training provisions of 1910.30 mostly apply to workers who use personal fall protection
systems, so not every employee will need training. For example, people who work on an
mezzanine protected by guardrails don’t need training on personal fall protection; they’ll
simply rely on the guardrails.
Fall protection systems that require training include:
• Personal fall protection systems (fall arrest, travel restraint, and positioning systems);
• Safety nets;
• L adder safety systems;
• Portable or removable guardrail systems; and
• Designated areas.
Fall protection systems and equipment are effective only when installed, inspected, used,
maintained, and stored properly. Workers need specific knowledge to perform these tasks
correctly. For workers who use these systems, train each affected employee on:
• Fall hazards in the work area and how to recognize them;
• Procedures to minimize those hazards;
• Procedures for installing, inspecting, operating, maintaining, and disassembling the fall
protection systems used; and
• Proper use of personal fall protection systems and equipment including hook-up,
anchoring, tie-off techniques, inspection, and storage.
For example, employees using a designated area on a flat roof need training on how to
properly set up and use that system. You’ll need to provide the necessary equipment such
as warning lines, and show employees how and where to set it up. In addition, you must
implement and enforce a work rule prohibiting employees from going within 15 feet of the
roof edge without using other fall protection.
Note that fall protection equipment specifications appear in Subpart I, Personal Protective
Equipment. For instance, 1910.140, Personal Fall Protection Systems, covers strength
ratings for D-rings and snap-hooks, and other requirements for system components. That
section does not mention training, but does require that employees inspect fall protection
components for damage or defects before use.
Specific training situations
In addition, 1910.30 requires training as specified in other sections of Subpart D. Most of
those other sections refer back to 1910.30, and apply only in specific situations. They apply
to workers:
• Using scaffolds and rope descent systems;
• On residential roofs where using fall protection isn’t feasible;
• Under special conditions where dockboards are used only for motorized equipment;
• Around repair, service, and assembly pits less than 10 feet in depth;
WALKING-WORKING SURFACES TRAINING:: PROTECTING WORKERS FROM FALL HAZARDS
3
• In outdoor advertising (like billboards); and
• On slaughtering facility platforms.
Employees working in any of these situations will require training specific to the hazards.
For example, the regulations state that employees working around a vehicle service pit do
not need fall protection if you limit access to authorized employees who received training
according to 1910.30. You would also need to provide floor markings and/or warning lines,
and post signs warning of the open pit.
DELIVERING TRAINING
You must train workers before initially assigning them to a job where they may be exposed
to a fall hazards. You must also deliver training in a language and vocabulary that each
worker understands.
OSHA doesn’t specify a required duration for training under Subpart D. Training should
take as much time as needed to convey all required information and make sure employees
understand the material. That might require only 10 minutes, or it could take an hour. The
duration will depend on the hazards that need to be covered and the type of equipment
used.
You may deliver training using a number of different formats (classroom, demonstration,
video) or technologies (online, interactive computer-based, web-based) provided that:
• It’s delivered in a manner each worker understands; and
• A qualified person developed or prepared the training.
If you provide web-based or computer-based training, a qualified person must be
available to answer questions from trainees. Keep in mind that it is the trainer who must be
qualified, not the training materials used. The trainer could use as many types of formats or
technology as necessary to ensure effective worker training.
Subpart D does not require keeping records of training delivered. However, keeping
OSHA requires that
a qualified person
deliver the training
records of all safety and health training helps demonstrate compliance with the applicable
standards.
Qualified person
OSHA requires that a “qualified person” deliver the training, and offers the following
definition:
Qualified describes a person who, by possession of a recognized degree, certificate,
or professional standing, or who by extensive knowledge, training, and experience has
successfully demonstrated the ability to solve or resolve problems relating to the subject
matter, the work, or the project.
Employers must consider a potential trainer’s background and determine if that person
is qualified. The qualifications could come from training, experience, or a combination
of both. Trainers do not need a specific degree or certification, as long as they have the
necessary knowledge, training, and experience.
OSHA noted that crew chiefs, supervisors, operations personnel, or other staff could train
WALKING-WORKING SURFACES TRAINING:: PROTECTING WORKERS FROM FALL HAZARDS
4
workers, provided they possess the knowledge and experience to meet the definition
of a qualified person. Alternatively, employers may use outside personnel to deliver
training, if the trainer is a qualified person. Contracting with outside personnel could
provide the necessary expertise after installing new equipment or adopting a new fall
protection system.
RETRAINING
OSHA does not require annual retraining, nor any other scheduled refresher training.
However, OSHA does require retraining whenever circumstances indicate a need for it.
The regulation lists several reasons that trigger a need for retraining. These include:
• The employee does not have the understanding and skill required;
• Changes in the workplace make previous training obsolete;
• Changes in the fall protection systems or equipment require additional training; or
• An employee’s knowledge or use of fall protection indicates a problem.
Indications of a need for refresher training might include improperly using equipment or
not using the equipment at all. For example, if worker used a portable ladder improperly
OSHA says that
maintaining
worker proficiency
is an ongoing
responsibility of
employers
by standing on a top step, retraining would be necessary. Similarly, employees using
defective or damaged equipment because they didn’t properly inspect it would need
additional training. And of course, if someone falls and gets injured, that suggests a need
for more training.
In short, whenever a change in workplace operations or equipment makes previous
training obsolete, or whenever you believe that a worker would benefit from additional
training based on a lack of knowledge or skill, retraining should be provided.
ENFORCEMENT
During an inspection, an OSHA compliance officer will determine whether the training
provided meets the requirements and intent of the specific standard, considering
the language of the standard and all of the facts and circumstances of the particular
workplace.
Compliance officers will look beyond documentation. They may interview employees
since training records cannot verify that employees understood the training. If employees
cannot satisfactorily answer those questions, the compliance officer could issue a
citation. Evaluate the effectiveness of your training programs before that happens.
TRAINING PREVENTS INJURIES
Falls have long been a significant hazard in general industry workplaces. Each year,
thousands of incidents result in lost work days, disability, and even death. Delivering
effective training can help avoid a costly citation. More importantly, properly trained
workers who consistently follow their training are less likely to get injured. Training is not
just required by OSHA — it helps keep everyone safe.
WALKING-WORKING SURFACES TRAINING:: PROTECTING WORKERS FROM FALL HAZARDS
5
HOW WE CAN HELP
As the nation’s leader in regulatory compliance and best practices expertise, J. J. Keller is your reliable source
for help protecting employees and reducing the risk of accidents and violations. In addition to OSHA, we cover
DOT, EPA, DOL, and other agencies.
Walking-Working Surfaces: What Employees Need to Know
This interactive online training program helps employees understand OSHA’s Walking-Working
Surfaces Rule and how it impacts their day-to-day job responsibilities.
PREVIEW ONLINE COURSE
ADDITIONAL FORMATS AVAILABLE!
Walking-Working Surfaces: What Supervisors Need to Know
This interactive online training program familiarizes managers and safety personnel with their
responsibilities under OSHA’s Walking-Working Surfaces Rule. It covers hazard assessment,
inspections, fall protection, training, and more.
PREVIEW ONLINE COURSE
ADDITIONAL FORMATS AVAILABLE!
Fall Protection for General Industry
This interactive online training program provides a high-level overview of OSHA fall
protection requirements. Specifically, it outlines potential hazards and protective measures
employees can take to prevent injuries on the job.
PREVIEW ONLINE COURSE
ADDITIONAL FORMATS AVAILABLE!
J. J. Keller® Training
For up-to-date, consistent training content, look no further than J. J. Keller® Training.
Whether you prefer classroom training with streaming video or self-paced learning with
online training courses — or a combination of both — we’ve got you covered.
START TRAINING TODAY
For more information, call 800-327-6868 or visit JJKellerTraining.com
6
ABOUT THE AUTHOR
ED ZALEWSKI, J. J. KELLER & ASSOCIATES, INC.
Ed joined J. J. Keller & Associates, Inc. in 1999 and currently specializes in safety
issues such as injury recordkeeping, walking-working surfaces, and forklifts. He is
responsible for researching regulatory activity and issues facing EHS professionals
in order to develop and update content for J. J. Keller’s EHS products.
Ed regularly publishes articles in trade magazines, delivers webcasts on a variety of
compliance topics, and delivers presentations. He has been published in or been
interviewed for articles by Bloomberg Businessweek, Monster.com, Australian
Financial Review, NDTV.com (New Delhi Television), Scripps Howard News
Service, SHRM Online, Diversity Executive, Talent Management, Workplace HR &
Safety, and newspapers such as the New York Post, Denver Post, Atlanta JournalConstitution, and Pittsburgh Post-Gazette.
Before joining J. J. Keller, Ed worked as a project manager for an environmental
consulting firm. He was responsible for investigating petroleum spills and
establishing action plans for environmental restoration.
ABOUT J. J. KELLER
Since its beginning as a one-man consulting firm in 1953, J. J. Keller
& Associates, Inc. has grown to become the most respected name in
safety and regulatory compliance. Now over 1,500 associates strong,
J. J. Keller serves over 600,000 customers — including over 90% of the
Fortune 1000® companies. The company’s subject-matter expertise
spans nearly 1,500 topics and its diverse solutions include training via
online courses, streaming video or DVD; online management tools;
managed services; advisory services; publications; E-logs and mobile
technology; and forms and supplies.
Safety professionals rely on J. J. Keller’s in-house expertise and
wide selection of products and services to reduce risk and improve
regulatory compliance, performance management, and operational
efficiency. For more information, visit JJKeller.com.
CONNECTWith
WITH Us
US ON
Connect
On
Copyright 2018 J. J. Keller & Associates, Inc. All rights reserved.
This document must not be reproduced in whole or in part without the written permission of J. J. Keller & Associates, Inc. Government regulations change frequently; therefore, J. J. Keller cannot assume responsibility
or be held liable for any losses associated with omissions, errors or misprintings in this publication. This publication is designed to provide reasonably accurate information and is distributed with the understanding
that J. J. Keller is not engaged in rendering legal, accounting, or other professional services. If legal or other expert advice is required, the services of a competent professional should be sought.
50374