Keith Vidal, M.S., P.E., CXLT, is chair of the ANSI Accredited A1264 Standards Committee. He recently spoke with ASSP about the ANSI/ASSP A1264.1-2017 standard, which addresses walking and working surfaces.
Q: Falls from heights and on the same level (a working surface) are among the leading causes of serious work-related injuries and deaths. Discuss the scope of A1264.1 and the types of workplaces in which the standard can have the greatest impact.
Keith: Although statistics vary slightly from year to year, and from source to source, there is no dispute that falls take a heavy toll on our society. The latest data from Liberty Mutual show they extract more than $15 billion in direct costs, and much more than this when considering total workers’ compensation and medical costs.
Although fatal falls from an elevated surface are more numerous (and generally more injurious) than falls on the same level, they are both of concern. ANSI/ASSE A1264.1, Safety Requirements for Workplace Walking/Working Surfaces and Their Access; Workplace, Floor, Wall and Roof Openings; Stairs and Guardrail/Handrail Systems, and its companion standard A1264.2, address the basic elements of preventing falls through a process and design approach.
The standard’s scope “sets forth safety requirements in industrial and workplace situations for protecting persons in areas/places where danger exists of persons or objects falling from elevated walking and work surfaces such as floor, roof or wall openings, platforms, runways, ramps, fixed stairs or roofs in normal, temporary and emergency conditions.” The breadth of the scope may seem wide in context of the area of concern. However, the standard’s purpose is quite simple: To establish minimum safety requirements for walking areas to provide reasonable safety of workers and others pursuing foreseeable activities.
The standard’s title may imply that it is solely for industrial work environments, but it is also intended as a guide for industries in which pedestrians other than workers may be present, such as commercial and retail environments where the public or other invitees may be exposed to fall hazards. Use of this standard over time will hopefully help reduce slips, trips and falls in environments where such hazards exist.
Q: OSHA recently updated its Walking-Working Surfaces and Personal Fall Protection Systems rule. In the Federal Register announcement of the rule, the agency stated that it drew many provisions in the final rule from consensus standards including A1264.1-2007. Discuss how OSHA’s rule and the consensus standard are similar and in what significant ways they are different.
Keith: OSHA’s new rule requires employers to set up the workplace using methodologies consistent with the intent of A1264.1: To prevent falls from platforms and other working surfaces, and prevent falls into floor and wall holes. It requires that employers provide handrails, stair rail systems and guardrail systems on stairways, with uniform riser and tread dimensions.
The similarities extend into requirements that walking/working surfaces be inspected “regularly and as necessary” to maintain the surface in a safe condition, and to correct or repair the hazardous condition, or to guard or barricade it before use is allowed.
Most significantly, in the context of A1264.1, OSHA’s rule eliminates the existing mandate to use guardrails as a primary fall protection method and allows employers to choose from accepted fall protection systems they believe will work best in a situation/application. The new rule attempts to align fall protection requirements for general industry with those for construction, easing compliance for employers who perform both types of activities.
OSHA’s new rule does not address the specific issue of measuring slip resistance nor does it elaborate on required levels of adequate slip resistance.
Q: What were the committee’s goals with this revision? What are some major updates/changes?
Keith: ANSI requires that standards be updated standard through review of the entire document and action to revise or reaffirm it on a schedule not to exceed 5 years, with extension to no longer than 10 years, or it is withdrawn as an American national standard. The committee aimed to produce a revised standard that was current with existing technology and industry standard performance requirements, and at the same time more easily read and utilized by users.
The standard’s organizational format was changed to make it more readable and less redundant. We also updated the performance requirements to be more consistent with existing codes and regulations, as well as current with advancements in technology with respect to human factors and scientific research.
Q: Why is this an important standard for OSH professionals to be familiar with?
Keith: The A1264 standard has a long history and came about as a consolidation of the A12 and A64 standards that have been around since the 1960s. A12 addressed requirements for railings, toe boards and wall openings, and A64 focused on specifications for industrial stairs. During the 1970s, the two standards were consolidated into one document, the A1264.1 standard. So, the standard has a history of more than 50 years plus, and has been widely recognized and used in both the private and public sectors. It is now referenced by OSHA in numerous regulations related to fall prevention.
Voluntary consensus standards have the distinct advantage over government-promulgated legislation and regulations in that they are generally more up to date with technology, research, and proven, advanced safety methodologies. They are not subject to the bureaucratic process that tends to make OSHA standards lag significantly behind these advancements.
OSH professionals should be knowledgeable of this standard because it is a step ahead of OSHA regulations in perhaps nuanced ways. It is those nuances that make our work environments safer for workers and the public. These small evolutionary advancements that make the world safer for everyone, and the next iteration of a standard even better than the last. Given the costs associated with falls and fall claims, this standard is an extremely important tool in terms of reducing same level falls, as well as falls on stairs, on elevated surfaces, or through floor or wall openings.
No standard, legislation or regulation is ever perfect. We will always strive to move ever closer, knowing that the goal may move further from us as technology and methodologies advance. Using good engineering and safety judgment, this standard provides an excellent resource to continue along that path and make the world safer one small step at a time.
Keith Vidal, M.S., P.E., CXLT, is chair of the A1264 Accredited Standards Committee. He is the owner of Vidal Engineering LC, a safety/engineering consulting firm based in St. Louis, MO, that specializes in design/safety consulting, forensic consulting and standards development related specifically to pedestrian safety. He holds a B.S. and an M.S. in Mechanical Engineering, both from the University of Nebraska. Vidal is a professional member of ASSP’s St. Louis Chapter and was named ASSE’s Edgar Monsanto Queeny Safety Professional of the Year in 2006.