New OSHA Rules For Floor Safety
Updated guidelines say floors should be inspected by “qualified persons.”
In August 2013, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) is scheduled to release new rules for Walking and Working Surfaces (29 CFR Part 1910), that raise the bar for floorcare, safety and inspection.
Subpart D of 29 CFR part 1910, Walking and Working Surfaces… “sets forth general industry requirements for employers to protect employees from slips, trips and falls…”
In developing revised rules, OSHA held hearings and conducted extensive scientific and technical research to inform a definitive approach to help protect workers from slips, trips and falls.
OSHA consulted sources such as the National Bureau of Standards (now the National Institute of Standards and Technology) and the American National Standards Institute (ANSI), which the agency used to develop the proposed revisions to subparts D and I.
Past studies referenced by OSHA in its new walkway rules include those produced by ANSI (e.g., ANSI A1264.2-2001 - Standard for …Walking/Working Surfaces), the University of Michigan (e.g., A Bibliography of Coefficient of Friction Literature Relating to Slip Type Accidents; Department of Industrial and Operations Engineering, College of Engineering, University of Michigan) and many others.
These studies established a foundation for OSHA’s earlier traction recommendations to help ensure a safe walkway, however, no coefficient of friction (COF) value was ever required or enforced by OSHA; a nonmandatory coefficient of friction is listed in the appendix of OSHA rules.
(See also the March 2003 OSHA rules “interpretation letter” from Richard E. Fairfax, director, OSHA Directorate of Enforcement Programs, explaining the nonmandatory nature of the COF recommendation in the walkway-rules appendix.)
Although the earlier rules were authoritative in the 1980s at the time of development, OSHA felt that — due to significant increases in the reported number of workplace falls — it was time to revise their requirements.
Qualified Person Required For Inspections
Under the proposed new rules, OSHA will now require that: “Only qualified persons shall be permitted to inspect, maintain or repair walking and working surfaces…”
OSHA defines a qualified person as one “capable of identifying existing or potential hazards in specific surroundings or working conditions which may be hazardous or dangerous to employees; and has been trained for the specific task assigned.”
What’s Inspection Got To Do With It?
OSHA’s proposed new rule will require that:
a. An effective housekeeping program (including floorcare) is needed.
b. That a “qualified person” is required to perform walkway inspections.
It is clear that — by OSHA mandate — every employer will be required to designate a qualified person to inspect their walkways to ensure they are in compliance with the newly referenced ANSI standards.
Walkways with a wet SCOF of 0.60 or greater or wet DCOF of 0.42 or greater are defined as “High-Traction” under the ANSI/NFSI B101.1 and ANSI/NFSI B101.3 standards respectively.
Where Can You Get Trained To Be A Qualified Person?
The National Floor Safety Institute (NFSI) was one of a few select organizations invited to present recommendations to OSHA at their final public hearing.
NFSI thus supports OSHA’s revisions to subpart D Walking and Working Surface requirements.
Anticipating associated training needs, NFSI has increased the availability and scope of its authoritative Walkway Auditor Certification Training through new training facilities in Southlake, Texas.
NFSI is in the final stage of becoming an official ANSI Accredited Training Organization, and in late Fall 2013 will be addressing the need for training qualified persons through its soon to be released Walkway Safety Management training program which is based on the proposed ANSI/NFSI B101.8 “Floor Safety Management Program for Slip, Trip and Fall Prevention.”
What Choice Do I Have In Field Measurement Devices?
NFSI recently published an up-to-date list of NFSI-approved tribometers to enable effective field measurement of walkway traction, based on the wet Coefficient of Friction (COF) of floors, as part of a comprehensive floor safety program.
NFSI applauds OSHA for stepping up with new rules that require qualified persons to inspect floors with the goal of raising floorcare to floor safety.
For more information on becoming a qualified person to inspect floors, contact NFSI to learn more about training programs.
Russell J. Kendzior — an internationally recognized leading expert in slip-and-fall accident prevention — is the president and chief executive officer (CEO) of Traction Experts Inc. and founder of the National Floor Safety Institute (NFSI). Sought nationwide as a safety consultant, public speaker and expert witness, Kendzior is the author of the best-selling book on accident prevention entitled, Slip and Fall Prevention Made Easy (Government Institutes, Inc., 1999) as well as the book entitled, Falls Aren’t Funny.
Definition of High Traction
The physical property of a floor or walkway that is designed to mitigate slipping during normal human ambulation by providing a reasonably sufficient level of available contact friction.
U.S. Department of Labor
Occupational Safety & Health Administration
March 21, 2003
Thank you for your November 15, 2002 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP).
This letter constitutes OSHA’s interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence.
You had a question regarding the static coefficient of friction (COF) for walking/working surfaces.
Question: Can OSHA provide any perspective or background on how the COF 0.5 value came to be attributed to OSHA?
Response: OSHA does not have any standards that mandate a particular COF for walking/working surfaces. While there are devices to measure the COF, no OSHA standard specifically requires that employers use or have them. As you may know, there is a nonmandatory appendix (Appendix A to Subpart D) in the Notice of Proposed Rulemaking for Walking Working Surfaces for general industry that discusses COF. Although the notice of proposed rulemaking was published on April 10, 1990, the final rule has not yet been issued.
The pertinent portions of the nonmandatory appendix read as follows:
Note: The following appendix to Subpart D serves as a nonmandatory guideline to assist employers in complying with these sections, and to provide other helpful information. This appendix neither adds to nor detracts from the obligations contained in OSHA standards.
2. Slip Resistance. A reasonable measure of slip-resistance is static coefficient of friction (COF). A COF of 0.5, which is based upon studies by the University of Michigan and reported in the "Work Surface Friction: Definitions, Laboratory and Field Measurements, and a Comprehensive Bibliography," is recommended as a guide to achieve proper slip resistance. A COF of 0.5 is not intended to be an absolute standard value. A higher COF may be necessary for certain work tasks, such as carrying objects, pushing or pulling objects, or walking up or down ramps.
Slip-resistance can vary from surface to surface, or even on the same surface, depending upon surface conditions and employee footwear. Slip-resistant flooring material such as textured, serrated, or punched surfaces and steel grating may offer additional slip-resistance. These types of floor surfaces should be installed in work areas that are generally slippery because of wet, oily, or dirty operations. Slip-resistant footwear may also be useful in reducing slipping hazards.
Although this discussion of COF appears only in a nonmandatory appendix in a rulemaking proposal, it appears to have been the basis for a statement included in an advisory appendix to the ADA Accessibility Guidelines (ADAAG) of the Access Board.
The appendix statement (at A4.5) is as follows: “The Occupational Safety and Health Administration recommends that walking surfaces have a static coefficient of friction of 0.5.” Together, OSHA's rulemaking proposal and the reference in ADAAG probably account for the attribution of a 0.5 COF to OSHA.
Thank you for your interest in occupational safety and health.
We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations.
Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations.
This letter constitutes OSHA's interpretation of the requirements discussed.
Note that our enforcement guidance may be affected by changes to OSHA rules.
Also, from time to time we update our guidance in response to new information.
To keep apprised of such developments, you can consult OSHA’s website at www.OSHA.gov. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.
Richard E. Fairfax, Director
Directorate of Enforcement Programs