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OSHA Revises Walking-Working Surface and Fall Protection Standards

Painters at Old Well
Photo courtesy of the UNC-Chapel Hill Multimedia Library.
Falls from heights and on a working surface continue to rank third in workplace fatal incidents in the state of North Carolina. To better protect workers, OSHA has revised the Walking, Working Surface Standard by providing clarification and updating to current technology and industry best practices. The main benefit to the general industry is that it provides employers with the flexibility of selecting the best fall protection system versus the mandate for guardrails systems which may not be the most appropriate in all situations. Additionally, there is better alignment of 1910 General Industry and 1926 Construction Industry standards when some employers, like UNC, perform both types of work activities.

EHS developed a new training program and trained more than 500 employees including some staff from UNC-TV. The training consisted of a side-by-side comparison of the old language to the updated version of the standard, which emphasized clarification, flexibility and prevention. An important example is the revised standard for parapet walls. To eliminate confusion on how to calculate if a parapet wall met compliance, OSHA has now standardized parapets to be 42 inches, plus or minus three inches. This aligns with any guard rail safety requirements. OSHA flexibility was introduced with terms on temporary or infrequent requirements for designated areas on low or flat slope roof access. The revised standard now allows employees to access the area if six feet to 15 feet is maintained from the roof’s leading edge. The most significant change that will heighten prevention is the requirement that a hazard assessment must be performed by the supervisor prior to the job task. This hazard assessment will assist supervisors in pre-job briefings and to formulate a more in-depth Rescue Plan versus just a statement to call 911. Although fall protection has been a priority for the University, EHS believes the revision to the Walking-Working Surface and Fall Protection standards will not only facilitate clearer communications regarding regulations but improve prevention by other campus units.

Performance measurement is a critical part of the EHS management system. Education, customer service and internal processes are the three most essential components of our work. The chart below indicates the performance in these areas over a five-year period with Level Four representing optimum performance. The adjacent tab shows the specific performance activities and the level of that performance for 2017.

Components, Years and Level Completed
Education Customer Service Internal Processes
2013 2014 2015 2016 2017 2013 2014 2015 2016 2017 2013 2014 2015 2016 2017
4 4 4 4 4 4 4 4 4 4 4 3 3 3 4


  • Trained/Number of Employees:
    • Respiratory Protection: 1,323
    • EHS Office, Clinic, IMAC, SS, Student Affairs: 4,516
    • Joint Commission: 4,233
    • Clinical Tuberculosis Infection Control: 6,425
    • Clinical Bloodborne Pathogens: 6,205
    • Ergonomic Self-Evaluations: 44.
  • Provided the following training: CPR/AED, PPE, Machine Guarding, Ladder Safety, HMP plans, Bloodborne Pathogen, Scissor Lift, Hazardous Materials.
  • Provided Manual Propelled Lift training for 51 “For the Kids” Dance Marathon student fundraising, 50 for Memorial Hall, 6 for Student Union.
  • Provided UNC Electrical Safety/NFPA 70 E compliance initiatives to OSHR, NCCU and Pembroke University.
  • Developed and provided training on OSHA’s revised Fall Protection standard.
  • Provided ergonomic training for department of Comparative Medicine seminar.
  • Provided Fall Protection training for UNC-TV staff.
  • Created the following JSAs: HMF Can Crusher; SOD Changing Hg Container, SOD Clearing Hg Contaminated Lines; Motor Scrubber Operation; Hydraulic Press, Hilt K-12 Concrete Saw; General use of Power Tools.
  • Provided healthcare compliance training to FS/BS, Nephrology, SOD, Emergency Medicine, Neurosurgery, Allied Health and Ortho.
  • Provided training regarding various compliance items for SOM and UNC Healthcare medical providers.

Customer Service

  • Processed and managed 492 workers’ compensation claims with medical treatment, return to work, hearings/mediations and monthly expenditures.
  • Conducted on-site inspections of 164 Hazards Management Plan (HMP) for numerous campus units and entered HMPs for work unit in the online HMP system.
  • Evaluated and reviewed the following construction projects: Med Wing E&F Project, Eddie Smith Field House, Wilson Library, Morehead Planetarium, Hamilton Hall, McColl, Morehead Chemistry, Hanes Art and New East.
  • Evaluated and prepared report on dust collection system for carpentry shop.
  • Assisted Campus Health Services regarding coding of healthcare personnel, respiratory protections and UEOHC billing for staff.
  • Provided consultative services regarding the following projects/events:  EHS Hazardous Waste Facility, Bowman Gray Pool, Davie Hall, Facilities Construction shops, ROTC, ITS Franklin; Cadaver Lab, Koury Dental, Memorial Hall, Wilson Library and Friday Center.
  • Investigated the following Hazard Hero submissions: Broken steps by Thurston Bowles, slippery storm drain at Hamilton Hall, broken steps by Fordham Hall; and damaged signs at Cardinal Deck.
  • Prepared and distributed safety alert for Powdered Medical Glove Alert.
  • Assisted Archeology department with safety questions and development of Hazards Management Plan.
  • Assisted payroll with out of State Workers’ Compensation coverage.

Internal Processes

  • Investigated 77 incidents: falls, equipment, PPE, materials handling, strains, and stuck in/between objects, etc.
  • Implemented modifications to training requirements for the School of Dentistry project.
  • Consulted with UNC General Administration regarding workers’ compensation and safety questions.
  • Continued consultation with UNC Healthcare LMS course designer regarding content of courses that affect School of Medicine employees, requirements, and database sharing to improve customer services.
  • Prepared and submitted OSHA 300A and other various OSHA random surveys.
  • Consulted with UNC -TV on the development of the Tower Climbing policy.
  • Prepared trending analysis based on injuries/near misses for Facilities Services.
  • Developed an action plan for the implementation OSHA’s new Crystalline Silica standard.  Evaluated tools currently used that may be impacted by the standard.
  • Prepared Job Safety Analysis development and internal approval process flow procedure.
  • Prepared injury/illness/near miss investigation process flow procedure.