Inspection requirements

• Employers must inspect walking-working surfaces regularly and as necessary to identify and correct hazards in a timely manner.

The Walking-Working Surfaces rule requires that all general industry employers conduct inspections. Essentially, if an employee uses a surface to walk on, work on, or gain access to an area in the workplace, it must be inspected.

An inspection is intended to identify and correct regulatory violations, reduce hazards, and help promote good relations with workers. Being proactive about finding and fixing hazards can help demonstrate a commitment to providing a safe workplace.

The Occupational Safety and Health Administration (OSHA) requires under 1910.22(d)(1) that inspections of all walking-working surfaces be done “regularly” and “as necessary” to ensure that they are in safe condition for employee use.

The term “regular inspection” means that an employer has some type of schedule, formal or informal, for inspecting walking-working surfaces that is adequate to identify hazards. OSHA allows employers to determine when and how often these inspections are conducted. Once an employer makes this determination, inspections must be conducted according to that frequency.

In addition, employers must also conduct inspections “as necessary.” This means inspections must be done when workplace conditions, circumstances, or events occur that warrant an additional check to ensure that walking-working surfaces are safe for employees use. These inspections would not be conducted at fixed times because situations could arise at any time that put workers at risk of slips, trips, and falls. For example, a stairway would need to be inspected if a forklift operator accidentally bumped the stairway.

The key is to ensure that walking-working surfaces are inspected often enough to identify and correct hazards in a timely manner.

A qualified person must perform or supervise any correction or repair that involves the structural integrity of a walking-working surface.

Documentation is not required for inspections, but it is considered a best practice to ensure that inspections are being done at the required frequency. Documentation also:

• Serves as a record of the company’s compliance,
• Allows a company to trace the history of a hazard(s),
• Helps identify trends (i.e., leading indicators) that could result in non-compliance if not corrected, and
• Aids in post-accident investigations.