Fall protection myths and misconceptions

When OSHA revised the regulations for Walking-Working Surfaces in 2016, the agency made quite a few changes. Since changes often generate confusion, we’re dispelling a few common misconceptions that we’ve seen on load limit plates, self-closing gates, and stairway railings.

Posting load limit plates

Just a few years ago, employers were required to post a plate on mezzanines or storage areas showing the weight capacity or load rating approved by a building official. However, OSHA removed that requirement from the Walking-Working Surface regulations in 2016; those plates are no longer required.

The new regulation simply requires employers to make sure each surface can support the maximum intended load. You can certainly leave existing plates up, but if you build a new structure or storage area, OSHA no longer requires posting a load capacity plate.

Self-closing gates

Another misconception involves the requirement for a self-closing gate or offset at the entry point to a fixed ladder. Some employers believe that a gate or offset is required only on fixed ladders over 24 feet.

OSHA considers a ladder opening a “hole” requiring fall protection (even if the ladder is at the edge of a platform) and fall protection is required when workers could be exposed to falls of four feet or more. That means any fixed ladder more than four feet high may need a self-closing gate or offset at the top access point.

Stair rail and handrails

Prior to the 2016 changes, many stairways had a single structure to serve as a handrail (for workers to hold) and to prevent workers from falling off an open side of the stairway. The revised regulation mandates at least one handrail which can be no more than 38 inches high, and a stair rail for fall protection on open sides, which can be no less than 42 inches high. Given these height discrepancies, a single railing cannot serve both purposes.

OSHA did allow existing stairs (in place as of January 17, 2017) to have one railing if it was at least 36 inches, but no more than 38 inches high. This was included so employers wouldn’t have to retrofit every stairway. However, that grandfather provision does not apply to newly installed stairways. Also, if the existing railing was under 36 inches, it should have been replaced with a compliant structure. This exception caused enough confusion that OSHA has plans to clarify the regulation with a proposed rule, expected in March 2021.

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