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2022 OSHA Inspection Prep Part Two: Indoor Fall Protection

• Aug 07, 2022

In our first installment of this series, we discussed how to prepare your rooftop for an unexpected OSHA inspection. With this edition, we’re turning our lens to your facility's interior, as indoor fall protection is just as critical as the fall safety on your rooftop. Falling at work is an unfortunate risk across a variety of industries — from warehouses to manufacturing plants to fulfillment centers and beyond. Even the most experienced and sure-footed employee can slip, trip, or fall if the right OSHA-compliant fall protection isn’t put in place.

Since OSHA’s mission is to ensure safe and healthy working conditions, it only makes sense to expect an inspection from time to time. To help you sail through your next one and, more importantly, protect your employees, let’s take a look at the four most common areas of concern when it comes to fall safety inside of industrial facilities: stairways, mezzanines, loading docks, and ladders.  

1. Stairways

Stairways present a risk in almost any work environment. With minds on the task at hand, busy employees often ascend and descend quickly with little regard to potential risk. In order to keep your team safe, be sure to check the following:

• Lighting. Dimly light stairways inherently raise the risk of falling—if your employees or visitors can’t see, it’s much easier to trip on the riser or nosing on the stair. Likewise, they may not see any other obstructions (which shouldn’t be there in the first place.)
• Treads & Risers. Stairway treads and risers should be uniform in size and have a visual contrast (like safety yellow) for easy visibility.
• Landings & Platforms. Stairway landings and platforms must be at least the width of the stair and at least 30 inches in depth as measured in the direction of travel. 
• Obstructions & Debris. Be sure your stairways are free from any obstructions and debris, and that surfaces are dry. 
• Safety Gates & Rails. Indoor safety gates and rails help control traffic flow, keep unauthorized persons out, and provide a grasping point to keep employees safe as they ascend and descend. OSHA states that stair rails installed before January 17, 2017 must be no less than 30 inches from the ledge edge of the tread, and 42 inches for rails installed after that date. 

2. Mezzanines

Both mezzanines and elevated platforms present their own risks. Employees working on them need to be mindful of the leading edge while workers beneath need to be protected from falling objects. Here’s how to make sure your mezzanine is in the clear for your next inspection:

• Consider the space. How is your mezzanine used? Is it for storage? Will employees perform work on it? What type of items will be moved to and from the platform? Is there a risk of falling objects to the level below? The answers to these questions will help you determine the appropriate indoor fall protection for the space.  
• Secure Open Ledges. If you haven’t already installed safety rails, now’s the time to do so. When it comes to guardrail systems, the top height of the rail should be 42 inches plus or minus 3 inches above the walking-working surface. (Note: in certain circumstances, the top edge height may exceed this number; see OSHA’s requirements here to see if yours meet the criteria). You also may need to install a toeboard, screens, or mesh to prevent the risk of falling objects. Keep in mind, toeboards must have a minimum vertical height of 3.5 inches as measured from the top edge of the toeboard to the level of the walking-working surface. (Note: a vertical height of 2.5 inches is allowable when used around vehicle repair, service, or assembly pits; check here to see the full requirements). 
• Add Indoor Safety Gates. Indoor safety gates allow for the passage of persons or objects while providing OSHA fall protection at the same time. Depending on your space and use requirements, you may opt for industrial swing gates or counterbalanced gates created especially for mezzanine use. Some are designed specifically for the passage of both people and objects, while others are engineered for only moving cargo —in either case, these specially-designed gates offer continuous protection even when in use. 

3. Loading Docks

OSHA is aware that loading docks are generally high-use spaces. Whether your workers are loading or unloading, it’s important to protect them from injury—and the same goes for the people making deliveries to your building. Here’s how to make sure your loading dock is ready for an inspection:

• Mark Floors & Edges. Yellow paint or tape can serve as a warning to workers to maintain a safe distance from openings and edges. 
• Ensure Surfaces Are Clean & Dry. Loading docks are often exposed to the elements. Ensure that your loading dock is free from debris, ice, water, or spills. 
• Prevent Falls. Like the areas above, loading docks should offer fall protection in the form of safety rails and gates. Fortunately, there are safety gates that are designed specifically for loading dock use—they are compliant with OSHA fall protection regulations, are easy to use, and allow for the passage of large cargo common in loading dock work areas. 

4. Ladders

Ladders present a fall risk and workers that use them—however infrequently—will need to be protected. Likewise, it’s up to you to keep unauthorized persons off. Here’s what to look for:

• Clear the Landings. Make sure the landing areas at both the top and bottom remain clear at all times. This will help prevent trips and falls for the ladder user, whether ascending or descending. 
• Keep Rungs Clean & Dry. Ladder rungs need to remain clean and dry to prevent slippage. 
• Guard the Ladderways. Ladders should be guarded with industrial swing gates and rails or ladder guards to ensure proper traffic flow and to prevent unauthorized usage.
• Install the Right Safety Devices. Keep in mind, that if the total length of the climb on a fixed ladder exceeds 24 feet, it must be equipped with ladder safety devices, self-retracting lifelines and rest platforms, or a cage or well. See OSHA’s guide to ladders here. 

Play It Safe

While passing an OSHA inspection may be your main goal, the real reason for these regulations is to protect the people behind your project. Failure to comply can result in costly fines and slowed timelines, but the real risk is putting your workers in harm’s way. With the right preparation and proper indoor fall protection in place, both your project and your people can remain full steam ahead.