Ever since revised Walking Working Surface regulations in 1910 Subpart D took effect in January of 2017, we’ve gotten a lot of questions about them. Finding the details you need can be confusing because Subpart D changed pretty drastically. OSHA renumbered a lot of sections, added quite a few provisions, and even removed many items.
In addition, the requirements are often spread throughout several sections. For example, ladders are covered in §1910.23 and stairways are covered in §1910.25. However, you’ll find additional requirements for ladders and stairways in §1910.28 and §1910.29. That means you may need to look in at least three different sections to find information you need.
A lot of the rules also require training, and many others imply a need for training. For instance, there is no specific requirement for training employees on how to conduct ladder inspections, but employees must understand how to perform those inspections properly.
The primary training regulation is §1910.30, which requires training employees who use personal fall protection. However, it also requires employers to provide training required by any other sections of Subpart D. Most of the other training provisions apply only in specific situations. They include:
In most cases, even those provisions primarily refer back to §1910.30.
Training must be delivered by a “qualified person.” The qualifications could be from training, experience, or some combination of both. Basically, the employer should consider the person’s background, and then determine if that person is qualified to deliver the training. There is no special certification required to be considered a “qualified” trainer.
If there are problems with the training delivered, OSHA can cite the employer for failure to deliver training. For example, if workers don’t seem to have the knowledge required to work safely (or someone got injured in a fall) then OSHA may question whether the training was adequate.