State Starting to Revise Work Area Access Rules in Response to Feds

Our company is preparing for extensive upgrading of its facilities, including access and work surfaces. Has California’s Occupational Safety and Health (Cal/OSHA) Standards Board adopted the new federal regulations published November 18, 2016 in Federal Register, Volume 81, No. 223, pages 82494–83006 addressing walking-working surfaces?

It should be noted that these regulations have not yet been adopted pending clarification as to the application to the maritime and agriculture regulations, which were exempted from the federal rulemaking. The Board is working to complete the process.

The federal Occupational Safety and Health Administration (OSHA) has extensively revised 29 Code of Federal Regulations 1910 Subparts D, I, N, and R.

Broad Coverage

These subparts address ladders, step bolts, manhole steps, stairways, dock boards, scaffolds, rope descent systems, fall protection, falling object protection, power and vehicle mounted platforms, man lifts, personal protective equipment (PPE), industrial trucks, pulp paper paperboard mills, textiles, sawmills and telecommunications.

Because of the number and different types of equipment and processes, the Cal/OSHA Standards Board opted to deal with the rulemaking progressively. The first rulemaking package addresses fixed and portable ladders, mobile ladder stands and scaffolds, stairways, step bolts and manhole steps.

When the regulations are adopted, they will apply to those areas and situations as published, and address the maritime industry’s concerns.

Proposed Revisions

• Section 3214, stair railings and handrails, has been revised, changing the height of the rails from the tread nose.

• Section 3234, stairways, has been revised to require a maximum tread height of 9½ inches and a minimum tread depth of 9½ inches, as well as platform/door encroachment clearance requirements.

• Major revisions have been made to Section 3277, fixed ladders. For example, the regulations address manhole rung length and separation, requirements for ladders that extend over 24 feet, cages and wells, and ladder safety systems. Because of the revisions, some definitions have been revised, such as alternating stairs, equivalent, toe board, and handrail. A definition for individual rung ladder has been added.

• A new Section 3279 has been developed to address the design, construction, installation and maintenance of stepbolts and manhole steps.

• Sections 3621 and 3622 address mobile ladder stands and scaffolds, reflecting new, revised, and repealed definitions which are indicative of industry terminology and operations.

• Sections 6564, 6599, 6600, and 6632 address the petroleum industry. The contents of Sections 6564 and 6599 have been repealed and replaced with language directing the user to revised Section 3277. Section 6600 now references Section 3279. Also, stirrup clearance and stepbolt spacing has been revised.

• Section 8608 of the telecommunication orders has been revised to reflect the development of new Section 3279 regarding stepbolts.

The proposal as presented at the June 2018 Cal/OSHA Standards Board public hearing may be seen at

Column based on questions asked by callers on the Labor Law Helpline, a service to California Chamber of Commerce preferred and executive members. For expert explanations of labor laws and Cal/OSHA regulations, not legal counsel for specific situations, call (800) 348-2262 or submit your question at

Staff Contact: Mel Davis