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1910 Subpart D – Walking & Working Surfaces

By Steve Stephenson

OSHA lists all their health and safety standards online. OSHA 1910 Subpart D discusses the safety requirements regarding the use of ladders, scaffolding, and general walking around worksites. There are ten sections you’ll need to become familiar with. 1910.21 Definitions. 1910.22 General requirements. 1910.23 Guarding floor and wall openings and holes. 1910.24 Fixed industrial stairs. 1910.25 Portable wood ladders. 1910.26 Portable metal ladders. 1910.27 Fixed ladders. 1910.28 Safety requirements for scaffolding. 1910.29 Manually propelled mobile ladder stands and scaffolds (towers). 1910.30 Other working surfaces. You can follow this overview of sections 1910.23 through 1910.30.

1910 Subpart D - Guarding Floor and Wall Openings and Holes

Openings through floors, roofs, and walls, with unprotected sides, are common during construction and renovation. If these openings are not guarded, people will get hurt. However, it's not just the obvious openings. A common cause of injuries and fatalities are falls through skylights. Any opening, through which someone can fall, even if there is something in the opening, must be guarded. The following are OSHA's recommendations:

  • Use a guardrail system, or
  • Use a fall protection system such as:
    • safety nets, or
    •  personal fall arrest systems, or
  •  Cover or guard floor (or roof) holes as soon as they are created.
    • Floor hole covers must be able to support twice the weight of the employees, equipment, and materials they might need to support.

OSHA recommends using fall prevention systems, such as guardrails, instead of fall protection systems, such as safety nets or fall arrest devices. A fall protection system provides a more secure and safe means of protecting people from falls.

1910 Subpart D – Fixed Industrial Stairs / Fixed Ladders

OSHA 1910.24 provides the specifications for fixed industrial stairs and ladders. This includes both interior and exterior stairs/ladders around machinery, tanks, and other equipment. It also includes stairs/ladders leading to or from floors, platforms, and pits. It does not cover fire exit stairs, articulated stairs (as used to access floating platforms), stairs in private residences, or stairs used for construction operations.

In general, this section ensures that fixed industrial stairs and ladders are of sufficient strength, size, angle, and design to be safe for their intended use.

1910 Subpart D – Portable Wood Ladders / Portable Metal Ladders

Accidents involving portable ladders are a leading cause of injuries and fatalities. Based on 1910 Subpart D, OSHA has a number of recommendations that should be followed to prevent portable ladder-related accidents.

  • Read all labels on ladders and follow their instructions.
  • Stay away from electrical hazards such as overhead wires and energized electrical equipment.
  • Inspect your ladder before using it. If the ladder is damaged, tag it and remove it from service.
  • Never use a step ladder as a single ladder, or in a partially closed position.
  • Never use the top step/rung of a ladder as a step, unless it is specifically designed to be used as a step.
  • Always keep three of your four hands and feet in contact with the ladder.
  • Always face the ladder when climbing or descending.
  • Only use ladders for their intended purposes. For example, do not use a ladder as scaffolding.
  • Keep ladders free of any slippery material on the rungs, steps, or feet.
  • Always place a ladder on a stable and level surface, unless it has been specifically secured.
  • Do not use boxes, barrels or other unstable bases to obtain additional height.
  • Do not move a ladder while a person or equipment is on the ladder.
  • A ladder used to access an elevated surface must extend at least three feet above the point of support.
  • The proper angle for a ladder is for the base to be a quarter of the working height from the vertical surface.
  • Be sure that all locks on an extension ladder are properly engaged.
  • Never exceed the maximum load rating of a ladder.

1910 Subpart D – Safety Requirements for Scaffolding

A scaffold is defined by OSHA as an elevated, temporary work platform. There are three basic types of scaffolds:

  • Supported scaffolds – these may have one or more platforms supported from the bottom by rigid, load- bearing members, such as poles, legs, frames, or outriggers.
  • Suspended scaffolds – these use one or more platforms supported from the top by ropes, cables, or other non-rigid, overhead support.
  • Other scaffolds – in some cases man-lifts and personnel hoists fall into the category of scaffolding.

The common hazards OSHA reports as being associated with scaffolding include:

  • Falls from elevation, usually as a result of fall protection;
  • Collapse of the scaffold, usually caused by instability or overloading;
  • Being struck by falling tools, work materials, or debris;
  • Electrocution, usually as a result of the scaffold being too close to overhead power lines.

Key provisions of OSHA 1910 Subpart D concerning scaffolding safety includes:

  • Scaffolding must have guardrails.
    • The top rail must be between 36 and 42 inches above the platform.
    • Mid-rails must be installed approximately halfway between the top-rail and the platform surface.
  • There must be toe boards that are a minimum of 4 inches in height.
  • Platforms must be fully planked or decked.
  • Scaffolds may not be altered or moved horizontally while they are in use.
  • If people are required to pass under, or work under a scaffold, the scaffold must have a No. 18 gauge U.S. Standard Wire one-half-inch mesh, or the equivalent, screen between the toe-board and the guardrail, along the entire opening, at the locations where persons may be beneath the scaffold.
  • No one may work on an outdoor scaffold during a storm or high winds.
  • Scaffolds may not be loaded in excess of their designed working load.
    • Scaffolds, and their components, must be capable of supporting at least four times the maximum intended load.
  • Periodic inspections must be conducted while the scaffolding is in use. Any damaged scaffold must be immediately repaired, and may not be used until it is repaired.

1910 Subpart D – Manual Mobile Ladders and Scaffolds

1910.29 states: “Specific design and construction requirements are not a part of this section because of the wide variety of materials and design possibilities. However, the design shall be such as to produce a mobile ladder stand or scaffold that will safely sustain the specified loads. The material selected shall be of sufficient strength to meet the test requirements and shall be protected against corrosion or deterioration.”

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