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OSHA Proposes Slips, Trips and Falls Regulation

By Jordy Byrd

The fatality ticker scrolls atop OSHA’s website, serving as an ominous reminder that gravity is a force to be reckoned with. Slips, trips and falls may appear to be innocuous workplace accidents, but fatality reports prove what a deadly threat these are.

Fatal slips, trips and trips took the lives of 699 workers in 2013, according to the most recent Bureau of Labor Statistics fatalities report. Falls to a lower level accounted for 574, or 82 percent, of those fatalities.

In June, OSHA plans to finalize a standard that addresses working surfaces and personal protective equipment (PPE) to prevent such accidents; meanwhile industry professionals are working to develop shoe standards which would scientifically measure the slip resistances of soles. But the push for regulation and research is all for naught without industry buy-in.

“Companies look at slips and falls as the third rail of safety,” said Russell Kendzior, president and founder of the National Floor Safety Institute (NFSI). “We as a society need to do better to prevent injuries.”

Proposed OSHA Regulation

OSHA has worked to revise slip, trip and fall prevention in the Code of Federal Regulations (CFR) for the last 25 years. Formal changes to the CFR were originally proposed in 1990 in an effort to not only address falling hazards, but establish requirements for personal fall protection systems due to advancements in technology.

The proposal was revised several times pending public hearings and was presented again in 2010. The current proposal aims to increase consistency between construction, maritime, and general industry standards.

OSHA is in the final ruling stage of 29 CFR 1910, subparts D and I regarding Walking/Working Surfaces and Personal Fall Protection Systems (Slips, Trips  and Fall Prevention) , which is set to become finalized and enforceable in June, 2015. OSHA estimates the proposed rule would prevent 20 workplace fatalities per year, and more than 3,706 injuries per year that result in days away from work – saving $155.4 million annually.

Current walking-working surfaces regulation allow employers to provide outdated and dangerous fall protection equipment such as lanyards and body belts, and prevent OSHA from fining employers who let workers climb certain ladders without fall protection.

Kendzior said the issue needs to be addressed, but procedures have taken more than 20 years and fails to address the severity and prevalence of falling accidents.

The numbers support the claim. Fall protection was the number one violation, resulting in 7,516 violations, according to OSHA’s top 10 most frequently cited standards in 2014.

“Why does this take so long, what’s the process, what’s the procedure?” Kendzior added. “This is a huge problem for the industry.”

NFSI is a non-profit founded in 1997 that aids in the prevention of slips, trips and falls through education, research, and standards development. In 2006, NFSI was accredited as a standards-developing organization by the American National Standards Institute (ANSI). Since that time, the NFSI/ANSI committee has developed a number of standards, and in 2014 NFSI became an accredited ANSI trainer.

“Falling is the biggest safety hazard for the top 10 industries,” Kendzior said. “We want to bring clarity to the subject matter so that walking surfaces can be monitored to prevent accidents.”

Kendzior said regulation can be an uphill battle. Companies often rely on insurance policies and lawyers to address falls as a liability issue, rather than a safety problem.

“Consistently throughout my career I have heard companies say, ‘yes, we have a slip, trip, and fall problem. It costs us each year,’” he said. “But the cost of claims is cheaper than fixing the problem. That’s human lives they openly acknowledge that are going to be injured...why is it that we just accept that as okay?”

Boots on the Ground

Walking and working surfaces are only part of the problem. OSHA’s proposed changes to 29 CFR 1910 Subpart I also address PPE.

With few exceptions, the existing standards do not specify the criteria for the design, operation, performance or use of PPE fall protection systems. Without such criteria, OSHA believes there is risk that personal fall protection systems – especially personal fall arrest systems – will fail.

The proposed rule would apply PPE requirements for general industry and addresses and defines subjects including: guarding floor and wall opening holes, fixed industrial stairs, portable wood ladders, safety requirements for scaffolding, training programs and more.

OSHA also proposes to amend a number of general industry standards that already require PPE, and to add examples of test methods and procedures that will help employers and PPE manufacturers demonstrate compliance.

As OSHA works to finalize regulation, researchers are examining footwear. Kendzior and the NFSI/ANSI committee members are working on a new standard B101.7 which would specify the procedures and devices used to measure footwear outsole slip resistance under wet or oily-wet conditions.

Researches use a device modeled after the Portable Slip Simulator – a robotic device that reproduces forces and sliding speeds similar to a human slip, a force plate – to test footwear slip-resistance.

“You can claim any sole is slip resistant but there is no standard of testing methodology,” Kendzior said. “The goal is to put the information in front of the consumer.”

The device is tested on multiple shoes and is used on oily or greasy surfaces like those in a fast food restaurant, and muddy, icy and slippery surfaces like those experienced on construction sites. The challenge is to develop slip-testing standards that are measurable, yet flexible enough to meet specific industry needs.

Breakthroughs have been made. Researches have begun measuring the fluid-pressures underneath shoes to determine if the shoe is experiencing hydrodynamic pressure (which is what happens when your tires hydroplane). This research determined that when shoes completely wear out, fluid pressures can develop underneath the shoe and the risk of slipping dramatically increases.

The NFSI/ANSI committee has also uncovered three other mechanisms relevant to shoe-floor friction which help create preventative flip and fall measures. Kendzior said the committee anticipates releasing a draft later this year and aims to have a standard published in 2016.

“Changing the footwear on employees is a helpful first step…” Kendzior says. “We are all just a step away from being the next victims ourselves.”

Slips, Trips & Falls Symposium

The National Floor Safety Institute and Emery University in Atlanta, GA will host a slips, trips and fall symposium featuring Former OSHA Director Ed Folk and keynote speaker Ralph Nader April 28, 2015. The event is open to the community and will feature research presentations, industry professionals and more.

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