On May 24, 2010, OSHA posted the "Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems); Proposed Rule."1 As business owners and safety professionals wonder how these changes will affect them, the stir created by the proposal process has fed a "Chicken Little—the sky is falling" atmosphere through the sales pitches of ill-informed safety consultants and product manufacturers. EHS professionals are asked to see past the fog and confusion to analyze if their company's focus points need to be adjusted. Time, money and effort all rely on an accurate portrayal of the compliance changes that will be brought about by the 2010 proposed revision of subparts D and I.
OSHA summarized the proposal of subparts D and I in this manner:
"The proposal reorganizes the rule in a clearer, more logical manner and provides greater compliance flexibility. The proposed rule is written in plain-language to make it easier to understand, thereby facilitating compliance. Additionally, the proposal increases consistency between construction, maritime, and general industry standards, and eliminates duplication."
It makes sense that the proposal keeps subparts D and I together. Subpart D establishes the walking-working surfaces requirements for general industry and advises the use of fall protection systems to protect employees from fall hazards while subpart I focuses on the fall protection systems performance.
