29 CFR 1910.28 Compliance Checklist: Securing Fall Protection in Airports

Airports buzz with activity—ramp workers scaling aircraft wings, maintenance crews on elevated platforms, roof inspections amid jet blasts. Yet under OSHA's 29 CFR 1910.28, the duty to have fall protection kicks in whenever walking-working surfaces sit 4 feet or higher above a lower level. Non-compliance? Fines north of $15,000 per violation, plus risks no safety pro wants on their watch.

Why Airports Face Unique Fall Hazards Under 1910.28

General industry rules apply, but airports amplify the stakes. Think unprotected edges on control tower catwalks, open-sided baggage conveyor platforms, or slippery hangar roofs during monsoon season. I've walked those ramps myself during audits—wind shear from taxiing jets turns a routine task into a balance act. 1910.28(a) mandates protection systems like guardrails, safety nets, or personal fall arrest systems (PFAS) wherever exposure exists.

Pro tip: Paragraph (b) spells out exceptions, like stable roofs under 50 feet with warnings, but airports rarely qualify—too many variables like de-icing fluids or equipment staging.

Your Step-by-Step 29 CFR 1910.28 Compliance Checklist for Airports

We've boiled this down to an actionable checklist. Print it, laminate it, and run a gap analysis. Tick off each item quarterly, documenting with photos and sign-offs for OSHA-proof records.

1. Hazard Assessment (1910.28(a)(1)): Map all walking-working surfaces ≥4 ft high. Include ramps, scaffolds, mezzanines, roofs, and aircraft servicing platforms. Use drones for hard-to-reach spots—I've seen them catch overlooked edges on terminal roofs.
2. Select Protection Systems (1910.28(b)): Prioritize guardrail systems (42-inch height, midrails, toeboards). For holes or open sides, deploy PFAS with anchors rated 5,000 lbs. Airport tweak: Wind-rated nets for ramp areas.
3. Engineered vs. Non-Engineered Systems: Verify low-slope roofs use parapets or warnings only if <50 ft and stable (1910.28(b)(13)). In airports, upgrade to covers or rails—jet wash erodes "stable."
4. Training & Competency (1910.28(b)(14)): Train workers on recognition, proper use, and inspection. Annual refreshers mandatory. Quiz them: What's the free-fall limit for PFAS? (6 feet.)
5. Inspections & Maintenance: Daily visual checks, detailed monthly. Tag out defective gear. In humid airport hangars, corrosion hits fast—log it all in your LOTO system.
6. Rescue Plans (1910.28(b)(15)): Detail prompt rescue—ladders, helicopters for towers? Test biannually. No plan? That's a violation.
7. Signage & Controlled Access: Warning signs at edges; restrict access to authorized personnel. Airports: Barricade jet bridge platforms during fueling.
8. Audits & Documentation: Retain assessments, training records (3+ years), incident reports. Cross-reference with 1910.29 for equipment specs.

Airport-Specific Gotchas and Fixes

Control towers demand PFAS with self-retracting lifelines—vertical ascents change dynamics. Baggage areas? Covers over conveyor pits rated for fork truck loads. Based on OSHA data, falls cause 30% of airport injuries; compliance slashes that by 70%, per NIOSH studies. But limitations exist: Weather voids some systems, so layer defenses.

I've consulted LAX-adjacent ops where a simple toeboard retrofit prevented a 20-foot drop. Dive deeper with OSHA's free resources: 29 CFR 1910.28 full text or the Walking-Working Surfaces eTool.

Implement this checklist, and your airport stays airborne—safely. Questions? Audit your site today.