Quick Guide to OSHA’s Fall Protection Standard Update (2017)

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The most significant change with the 2017 update is that the generic term for anything that is a mobile work platform is now called a “mobile ladder stand platform” (even if it has a staircase instead of a ladder). OSHA has also redefined standard railing as a “guardrail system,” and portable metal ladders are now “mobile ladder stands.”

Be sure to check out the employer deadlines at the bottom of this post and read more about the key five OSHA standards for industrial work platforms.

BASIC TERMINOLOGY

Old Terms New Terms
Manually Propelled Ladder Stands Mobile Ladder Stand Platform
Standard Railing Guardrail System
Portable Metal Ladder Mobile Ladder Stand

OSHA STANDARD 1910.21-30

Old §1910 Subpart D Standard Number New §1910 Subpart D
Scope and Definitions 1910.21 Scope and Definitions
General Requirements 1910.22 General Requirements
Guarding Floor and
Wall Openings and Holes
1910.23 Ladders
Fixed Industrial Stairs 1910.24 Step Bolts and Manhole Steps
Portable Wood Ladders 1910.25 Stairways
Portable Metal Ladders 1910.26 Dockboards
Fixed Ladders 1910.27 Scaffolds and Rope Descent Systems
Safety Requirements for Scaffolding 1910.28 Duty to Have Fall Protection and Falling Object Protection
Manually Propelled Mobile Ladder Stands and Scaffolds 1910.29 Fall protection Systems and Falling Object Protection – Criteria and Practices
Other Working Surfaces 1910.30 Training Requirements

EMPLOYER DEADLINES

  • May 17, 2017 | Training workers on fall and equipment hazards
  • November 19, 2018 | Installation of fall protection (personal fall arrest systems, ladder safety systems, cages, wells) on existing fixed ladders (over 24 feet) that do not have any fall protection
  • November 19, 2018 | Installation of personal fall arrest systems or ladder safety system on all new fixed ladders (over 24 feet) and replacement ladders/ladder sections
  • November 18, 2036 | Installation of ladder safety systems or personal fall arrest systems on all fixed ladders (over 24 feet)

Want a quick cheat-sheet for OSHA compliance? Download this free checklist!

OSHA Compliant Work Platform Checklist Download

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Five Key OSHA Standards for Work Platforms

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OSHA requirements for work platforms have always been complex. But since January 2017 when OSHA completely rewrote the standard 1910 Subpart D: Walking Working Surfaces.

Want an easy checklist to make sure your equipment is compliant? Download the 2017 OSHA Compliance Checklist here. 

OSHA Compliant Work Platform Checklist Download

The OSHA standard for fall protection had been in dispute in the decades leading up to the January 2017 final ruling. The basics of the update established the requirement for employers to protect workers from fall hazards along unprotected sides or edges that are at least 4 feet above a lower level. It also established requirements for the performance, inspection, use, and maintenance of personal fall protection systems.

Here is a list of five current OSHA standards for work platforms that you may not be aware of

1. Any working surface 4 feet or higher must be protected with guardrails on all sides at least 42″ tall.

OSHA 1910.29(b)(1): The top edge height of top rails, or equivalent guardrail system members, are 42 inches (107 cm), plus or minus 3 inches (8 cm), above the walking-working surface. The top edge height may exceed 45 inches (114 cm), provided the guardrail system meets all other criteria.
Mechanically attached foam protects personnel and assets.

This may be the quintessential OSHA requirement for work platforms. Any work area four feet or more above the next level lower MUST have guardrails. The guardrails must be on every open side of the platform, excluding openings. The only time railing is not required is when the platform is up against another vertical surface (like the side of a helicopter). In that case, it is still critical to ensure railing covers any gaps.

Don’t forget: when you’re performing manufacturing or maintenance tasks, there is a good chance you will be setting tools, parts, and hardware on the floor beside you. In order to prevent a wrench from falling off the platform and smacking a coworker on the head, 3-1/2″ tall toeboards are required on all open sides of the platform (excluding openings). Guardrail systems should also be capable of withstanding 200 pounds of force applied in a downward or outward direction.

2. The platform’s height cannot exceed 4x its base width.

OSHA 1910.23(c): The maximum work-surface height of mobile ladder stands and platforms does not exceed four times the shortest base dimension, without additional support.
Mechanically attached foam protects personnel and assets.

 

If you need to access something at a great height but have limited space, consider requesting a stand with extended caster beams that can slide underneath your equipment and maintain this 4:1 ratio. These outriggers will provide enough of a base to keep your platform stable. Some companies even offer inboard outriggers which can lift up and over obstacles on your equpiment, such as helicopter skids.

3. Stairs must be at least 16″ wide, 7″ deep, and have no more than 10″ of rise between them.

OSHA 1910.23(e)(1): Mobile ladder stands and platforms have a step width of at least 16 inches (41 cm). Steps are uniformly spaced and arranged, with a rise of not more than 10 inches (25 cm) and a depth of not less than 7 inches (18 cm).
Height control capable of vertical travel from 12 to 96 inches or more.

 

If you need a height-adjustable work platform with stair access, the best option for OSHA-compliance is a variable pitch staircase. The Spika-developed Variable-Pitch Staircase maintains consistent step interval at any height and ensures you comply with OSHA standards, no matter if you have 2 feet or 12 feet of vertical travel.

4. Self-closing safety gates are always required around openings (like ladder holes).

OSHA 1910.29(b): When guardrail systems are used around holes that serve as points of access (such as ladder ways), the guardrail system opening (1) has a self-closing gate that slides or swings away from the hole, and is equipped with a top rail and mid-rail or equivalent intermediate member, or (2) is offset to prevent an employee from walking or falling into the hole.

Self-closing safety gates are critical for OSHA compliance; you have to ensure that your technicians cannot back through a hole in the guardrail or push the safety gate open without intending to. Safety gates can either be spring loaded that close behind you when you enter the platform, or they can utilize latches for times when you have to have the safety gate open outward. For extra safety precaution, consider using an interlock mechanism to ensure the safety gate cannot be opened when it’s unsafe.

5. The platform must be tested to 4x its rated capacity.

OSHA 1910.23(e)(1): Mobile ladder stands and platforms are capable of supporting at least four times their maximum intended load.

Technicians can wonder if their work platform will fail them if they need to carry an excessively heavy tool onto the deck or need a little extra help from fellow technicians to perform a task. It’s highly unlikely that a failure like this will ever happen, as quality manufacturers of work platforms actually test the structure to 4x its load rating in-house to make sure there will be no failure before sending it to the customer.

The number of safety standards that apply to work stands can be overwhelming. If you’re unsure whether your platform is in compliance, ask the experts. It’s not worth risking injuries, fines, and decreased employee moral, and often one little fix can bring you into full compliance.

For more information on employer deadlines, new terminology, and at-a-glance guidelines for mobile work platform compliance, download the checklist below.

OSHA Compliant Work Platform Checklist Download

 

Are you interested in seeing what your OSHA-compliant work platform could look like?

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3 Features That Will Save You Money with Your Cantilevered Work Platform

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One of the most common access challenges technicians face, especially in manufacturing lines, is the need for cantilevered access at multiple levels. Because overreaching access requirements vary from project to project, cantilevered work stands have to be customized to the end user’s specs almost 100% of the time. Sometimes these requirements call for simply a “diving board” design that allows a technician to lie above a piece of equipment for access. Other applications, however, require a larger platform that has extensive overreach capabilities and can accommodate two or more technicians.

While there are plenty of cantilevered work platforms on the market that can hold multiple technicians at a time – the B Series platforms come to mind – the real challenge is finding a large overreaching work platform that provides vertical, cantilevered access without compromising on stability.


Below are the top three considerations you and your technicians should discuss before choosing a company to design and manufacture your cantilevered work platform.

1. Make sure the work platform is stable while in use.

Many existing cantilevered work platforms, by their very design, sacrifice stability due to extreme lengths of overreach from the foremost support points. Side to side sway, as well as “bounce” when working from the deck, increase the farther the platform is from the support points.

Look for a work platform that is designed with the front leg support member as close to the center of the load as possible. This type of design allows greater overreach, as well as greater width of the workspace, without the feel of instability. If necessary, add outrigger jacks to lock the stand in place and increase stability during use.

Depending on the design, certain cantilevered work platforms will utilize counter-balance weights.

2. Choose a work platform with reliable actuation.

Hydraulic actuation has been a popular method of actuation for cantilevered work stands. But hoses and seals age and deteriorate, causing leakage of hydraulic fluid, and because of aging components, hydraulics have the tendency to “seep,” or slowly settle over time. This can create a significant problem when the stands are positioned above vulnerable components or surfaces. These issues increase maintenance costs, but also increase the likelihood of equipment damage during use.

Consider using a work stand that has electric or manual actuation. For example, the RangerMax work platform utilizes a dual-acting telescopic linear actuator system. This unique design provides greater extension capability while retracting into a compact length. The 120VAC or 12VDC electric actuators provide smooth, predictable extension and retraction, and cannot back-drive or seep from the set extension. These systems are also virtually maintenance-free.

3. Ensure the work stand can be transported easily.

Users have found existing cantilevered work platforms are very difficult to maneuver in tight hangars and work areas, and it can be a struggle repositioning the work stand. Depending on your work environment, you might also be moving the stand over more rugged terrain, which can be nearly impossible if the stand isn’t equipped with the right casters.

 

For easy, manageable movement of your stand, look for a system that uses dual-disc casters. These casters allow easy movement of the platform both backward and forward and side to side, making positioning simple. Also, check for a system that uses high-quality face brakes to secure the system during storage. If required, request outdoor-rated casters.

Also, consider choosing aluminum. While aluminum is more expensive than steel, it’s roughly ⅓ the weight of steel, can be ribbed or extruded, and is corrosion resistant.


Additional Considerations

In addition to the above requirements, consider the following questions when sourcing your cantilevered access equipment:

  1. What is the lowest height at which you need your work platform to start? Many work platforms are designed with the lifting mechanisms underneath the deck, which limits its lowest height capabilities.
  2. How much cantilever capability do you need? There are various platform designs that provide cantilevered access, from a simple diving board design to the RangerMax stair with excessive overreach capabilities to a full-blown work platform with 24” or more of slider overreach. Do your research to make sure you’re finding the cantilevered access that fits your needs perfectly.
  3. What type of decking do you need?  Consider if your technicians will be working on their knees a lot, or will have slick shoes, etc. Manufacturers can add specific high-traction or draining deck tread to make sure your work platform remains safe in all working conditions. You can also request deck matting for technicians that will be working on their knees.
  4. Keep it OSHA-compliant. Since you’re getting an expensive piece of equipment, it should comply with OSHA’s standards to eliminate any potential issues while in use. Look for a manufacturer that meets or exceeds OSHA’s standards for mobile work platforms.

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Q&A with Rick Zaitonia, KUKA Systems Aerospace Group: Integrators Outsourcing Work Platforms

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Between the robotics required to build the equipment to the hundreds of tools necessary to support the manufacturing process, engineers are overloaded with developing customized systems and tools that not only satisfy the needs of the manufacturing line, but also meet or exceed safety standards, utilize ergonomics that promote efficiency, and employ cutting-edge designs that require little maintenance or repair.

Rick Zaitonia, Project Manager at KUKA Systems Aerospace Group, approached Spika about outsourcing the work platforms for their client. After the partnership concluded, Spika interviewed Zaitonia about the successes and challenges of outsourcing the custom work platform design and manufacturing for his facility.

How were you designing/manufacturing work platforms before you outsourced them?

Before Spika, we didn’t really have a need for a modular, portable work stand. We were using large steel work platforms, fixed in place, and at a fixed height, which we designed and built in-house. Rather than moving the stands to the aircraft, we’d pull the parts of the aircraft up to the stands.

What drove you to consider outsourcing the work platform part of the system?

When we started the helicopter program, that’s when we needed to use the same work stand at different heights. The way our assembly line process was, we didn’t need a large, fixed stand. We needed a portable, push-up stand.

If we’re at a high volume and there’s work we need to offload to keep moving forward, we’ll outsource — if we’re not over capacity, we’ll keep it in house.

Read the full case study here

What were your primary concerns about outsourcing the design and manufacture of work platforms?

When we went out looking for it, it was going to be just the cost, making sure that it would fit into the budget. Also, just the functionality and quality of the stands. Could we find something that could fit into our operations that was good quality and cost-effective.

What are the benefits of outsourcing the work platform portion of an assembly line?

Instead of us having to come up with custom designs for work platforms, we could go to the experts that already had the designs. We had a very complex large program and it freed up our resources to let the experts handle that portion and let us specialize in what we’re good at.

What would you caution people about outsourcing part of their design and manufacturing?

When you’re outsourcing something, it still reflects on your company, and you’re still responsible for the end product. We just have to make sure the outsourced product matches our standards. After finding Spika, our team did our homework and did a visit to the facility. One of our quality managers looked at the processes, quality reports, products, and system capabilities.

We had visited one other facility prior to Spika’s. Their product and end result looked really nice, but their company was small and their processes just weren’t there to meet the volume and demand.

What type of company do you want to partner with if you choose to outsource your work platforms?

The relationship with the outsourcing company is more of a partnership and team effort than a vendor relationship. There has to be that ability for the design team to communicate and handle the design reviews together. There has to be cohesiveness and transparency for it to work. There are no secrets, we’re not there to steal your intellectual properties.

Do you have any quantifiable results of money/time saved by outsourcing the work platform portion of your line?

It’s hard to quantify it due to the size of the project. I’ve had over 600-700 tools, so when you look at the work stand platforms, they may have been 10-15% of the project. In reality, we’re saving 10% of time because we’re not using up that resource.

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6 Tools Everyone in Lightweight Helicopter Maintenance Should Be Using

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When your next facility update arrives, consider incorporating the following items into your fleet of maintenance equipment.

1. Air and Electric Hookups

There are plenty of products on the market that offer small tool trays attached to the aircraft maintenance platform to make maintenance more ergonomic and efficient. While these tool trays do amplify efficiency to a degree, they don’t solve the problem of having to string cords and hoses across the facility to hook up air and electric tools. Providing on-board air and electric hookups for your techs saves a tremendous amount of time and eliminates the bulk of hazardous cords.

2. Tool-Free Guardrail Attachment

Since you have a small aircraft, your priority is getting the most bang from you buck, which means you need your maintenance stand to conform to all parts of your aircraft — including both sides and the tail. Because of the varying interfaces at those maintenance points, configurability is essential. For example, when placed directly against the side of a helicopter, no guardrails are required at the front. But when positioned for tail rotor maintenance, guardrails must be present on all sides of the platform to provide OSHA-compliant fall protection. To keep reconfiguration time to a minimum, consider purchasing an aluminum stand that has tool-free guardrail attachment — specifically, systems that come with fully-captured camlock-bolting guardrails. While pin and socket systems are “technically” tool free, they aren’t as user-friendly or stable. For an added bonus, get guardrails with hangers so they can be self-storing on top of the platform.

3. Telescopic Rails

Adding to the ease of reconfigurability, a stand that has telescopic railings offers the versatility you need to access all parts of your aircraft with only one stand. Vertically telescopic rails allow you to access difficult areas where obstacles such as rotor blades may limit clearance, while still providing the required 42” safety railing height around the rest of the work area. Horizontally telescopic rails provide 360° fall protection around curved aircraft surfaces, particularly when protecting the ends of extension slider sections, keeping you safe and OSHA-compliant.

4. Inboard Outriggers

The easiest way to boost efficiency is to make sure your equipment conforms precisely to the helicopter you’re maintaining. If you’re working on an OH-58, AS350, UH-72, H125, or another skidded helicopter, your maintenance equipment should have some type of support inboard of the skid to maintain stability.  While some stands can be lifted over the skid or interlocked by feeding around the front and rear separately, stands with rotating inboard outriggers provide fast, easy positioning and ultimate stability. Inboard outriggers are absolutely critical for maintaining stability when over-reaching skids. For added conformance to the helicopter’s surface, consider equipment that has deck extension sliders that extend independently.

 

5. Height Adjustability

This is where many companies decide to cut corners, and I can’t stress how much this feature will improve your safety and efficiency. If your tech has the right access at the right height, he or she won’t have to overreach, crouch, or balance precariously to get the job done. Many stands come with manual actuators that can adjust by at least 24”. (If you want to go fancy, you can invest in a stand that actuates electrically.) If you do choose maintenance equipment that has height adjustability, make sure systems utilizing stairs have maximum inclines of no more than 50° and maintain an equal distance between steps through all height settings. If the stand uses a built-in ladder (which offers a smaller overall stand footprint), make sure the ladder adjusts to all heights and doesn’t exceed a 20° pitch at any height.

Watch this video to see electric dual-stage actuation in action.

6. Adequate Deck Size

A lot of aircraft maintenance has been performed off of simple ladders or small ladder stands. While this is adequate in some applications, often it falls short of providing efficiency or preventing maintainers from reaching outside of the safe zone to access areas without moving their ladder. Working with a deck that is matched to the size of the area being accessed is critical to attaining desired task efficiency and minimizing injuries. An adequately sized work stand pays for itself fairly quickly.

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The Slider Revolution: Achieve Perfect Conformance with Work Platforms

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With the ability to extend out from a work deck to conform around equipment edges, sliders have proven especially useful on aircraft maintenance stands and other work platforms where straight decks leave dangerous gaps between the deck and the equipment.

Sliders have been a part of work platforms for many years. But if you think you know all there is to know about sliders and their benefits and challenges, you may want to think again. Very recently sliders have undergone a revolution, dramatically improving safety and ease of use.

The Original Sliders

The original sliders were far from user-friendly. After being positioned around equipment, each slider had to be individually secured in place using a friction lock under the deck. The setup of the sliders alone took a significant amount of time. In addition, they were often flimsy, and many facilities resorted to placing plywood over the sliders to decrease the flex. In short, they were usually more trouble than they were worth.

The Modern Version

In recent years, some manufacturers have developed a far superior slider. One big change is the slider locking method – a pneumatic slider locking system. Rather than securing each slider individually, the pneumatic system allows all sliders to be locked instantaneously with the flip of an air switch, and they remain secure even when air pressure is lost. If air service is not available, the sliders can be secured manually with a foot pedal or one turn of a wrench.

Some manufacturers have also significantly improved the strength of the sliders by using a sturdier material, virtually eliminating flex. Sliders now feel as secure as the deck itself.

The Thin-Volution

Today, a new revolution is hitting the work platform market. Whereas traditional sliders sit approximately 2” (5 cm) below the work deck, the new “thin-line” platforms have sliders that lay hardly over 1/8” (.3175 cm) below the main surface. This system decreases trip hazards and allows for closer fit up to equipment (due to the decreased deck size) for little to no extra cost.

2″ gap between deck and slider 1/8″ gap between deck and slider

Ultra Conformance

A second innovation in work stands is the introduction of ultra-conforming sliders. Traditional sliders are limited by the width of the material; the wider the slider, the greater the potential gap between deck and equipment. But even narrow sliders leave some gaps, especially on curved edges. The new ultra-conforming sliders are able to rotate to accommodate the shape of the equipment, which is particularly useful for curved surfaces on aircraft, space vehicles, and other similar equipment.

Controlled Precision Slider System

Spika’s latest and most precise slider system design allows users to adjust sliders to fractions of a millimeter while on top of the work deck. Using an intelligent gear structure, this system provides a smooth and accurate adjustment of the sliders. Watch a video of it in use.

Are you interested in work platform design? You may be interested in these other blog posts:

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Three Signs You Should Invest in a Dual-Stage Actuation Work Platform, Not a Scissor Lift

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When someone requires upper-level access with a large amount of height adjustability, they typically look at scissor lifts rather than work platforms. And for good reason – standard work platforms typically only allow height adjustment ranges of one to three feet. For example, they’ll start at 60” tall and adjust up to 84”. Any greater height range becomes difficult to achieve because 1) multiple actuators are required, 2) adjustability becomes physically difficult at greater ranges, and 3) it’s cumbersome to adjust both sides equally and at the same time.

However, Spika has introduced a new work platform design that utilizes dual-stage legs and provides a much greater range of adjustability than ever before (watch the video below). The platforms can be built with an actuation range of seven feet or greater, even when beginning from a very low level. For example, a platform could have a minimum height of 36” and raise up to 96” or greater, a range of 60”.

So when should you look into buying a dual-stage leg work platform rather than a scissor lift?

1.    You need to be able to work under the platform

Scissors lifts are not meant to be worked under. Not only is it dangerous, it’s virtually impossible. So what do you do when a coworker is working at an upper level and you need to install a component directly below them? You wait, that’s what. When using a work platform utilizing dual stage legs, you are able to work directly under the platform while others work above. This can be especially useful when manufacturing or maintaining equipment with multiple levels, such as aircraft.

2.    You require overreach

Though not common, some scissor lifts do provide overreach via sliders or deck design. However, the amount of overreach is fairly limited. Work platforms commonly provide sliders or overhang decks to allow overreach of obstacles, and that remains true when they are built with dual-stage legs. The distance between the front legs of the platform and the leading edge of the deck can be 48” or greater.

3.    You desire extra stability

Scissor lifts are based on sound design and engineering, but that doesn’t change the fact that the swaying can be uncomfortable. In addition, there is potential to damage nearby equipment if the movement is too great. However, even very tall work platforms typically feel much more stable than a scissor lift.

Of course, there are times when a scissor lift is the better option. These include times when height adjustability of ten feet or greater is required, or when you want to be able to drive the platform between locations.

However, particularly in maintenance and manufacturing industries, the new platform design may improve upper-level access in ways scissor lifts never could.

 

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