Fall Protection (1926 Subpart M)

The Open Hatch: 3 Walking-Working Surface Rules for Warehouses

By Black Belt Safety Editorial Team 2 min read

The story

Two P.M. in a busy distribution warehouse. Dana is restocking shelves on the storage mezzanine, about ten feet above the concrete floor. It is the last big order of the day, and the truck leaves at four. Earlier, someone opened the floor hatch on the mezzanine to pass boxes down, and left it open. A pallet jack has been leaking hydraulic oil next to the hatch all morning. Everyone has been stepping around the puddle.

What went wrong

  1. One: in general industry the trigger height is just four feet. Each employee on a walking-working surface with an unprotected side or edge four feet or more above a lower level must be protected from falling.
  2. Two: the open hatch was a hole. Each employee must be protected from falling through any hole four feet or more above a lower level by covers, guardrail systems, travel restraint systems, or personal fall arrest systems.
  3. Three: the spill. Walking-working surfaces must be maintained free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow, and ice. Stepping around it is not a fix.

Learn the full rules in the 20-minute Walking-Working Surfaces and Falls course.

The same day, done right

  • Here is the same afternoon, done right. When the boxes are down, the hatch is closed, and the guardrail around it is put back.
  • The mezzanine is inspected regularly and as necessary, and kept in a safe condition.
  • And when the oil leak is found, it is cleaned up before anyone uses that surface again. If it can’t be fixed right away, the area must be guarded so nobody walks through it.

Quick check

  1. In general industry, at what height must workers at an unprotected side or edge be protected from falling?
  2. How must workers be protected from falling through a hole 4 feet or more above a lower level?
  3. When must a spill on a walking-working surface be corrected?
Show answers

1) 4 feet or more. 2) Covers, guardrail systems, travel restraint systems, or personal fall arrest systems. 3) Before an employee uses the surface again.

Walking-Working Surfaces and Falls

About 20 minutes on a phone or computer. Pass the quiz at 80% and get a certificate.

Awareness training. The certificate records completion; it is not an OSHA card or a license. Sources: 29 CFR 1910 Subpart D (eCFR). Photos: U.S. government via DVIDS (public domain): Tech. Sgt. Julianne Sitterding, Ryan White, Jessica McClanahan, Staff Sgt. Frederick Brown, Lance Cpl. Laura Mercado. Appearance does not imply endorsement.

The Open Hatch: 3 Walking-Working Surface Rules for Warehouses

Written and reviewed by

Black Belt Safety Editorial Team

Site Safety Officer and Safety Professional

OSHA 30 · CPR · USACE CQM

Written and reviewed by the Black Belt Safety team. Every post is checked against the OSHA standard or agency source it cites.

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