5 Common Misconceptions About 29 CFR 1910.28 Fall Protection in Food and Beverage Production

In food and beverage plants, elevated walkways over mixing vats, catwalks around silos, and mezzanines above packaging lines create prime fall risks. OSHA's 29 CFR 1910.28 mandates fall protection for general industry walking-working surfaces, yet misconceptions persist, leading to citations and incidents. Let's debunk the top five myths I've encountered consulting for processors from craft breweries to massive dairies.

Misconception 1: Fall Protection Only Kicks In at 6 Feet

This is a classic mix-up with construction standards under 29 CFR 1926. In general industry like food production, 1910.28 requires protection for unprotected sides and edges 4 feet or more above a lower level. I've walked plants where operators shrugged off 5-foot drops to conveyor belts, citing the "6-foot rule."

OSHA's 2016 Walking-Working Surfaces final rule clarified this: no more phase-ins; compliance is immediate. In wet, slippery food environments, a 4-foot fall can turn deadly fast—think fractured skulls from concrete floors below blending tanks. Check your platforms; if they're 4 feet up, guardrails or covers are non-negotiable.

Misconception 2: Guardrails Aren't Needed on Temporary Platforms

Many assume platforms for maintenance—like those over bottling lines—are exempt if used briefly. Wrong. 1910.28(b)(1) demands fall protection systems on any walking-working surface with unprotected edges 4 feet high, temporary or not.

During a recent audit at a California winery, we found scissor lifts accessing tank tops without perimeter protection. Workers jury-rigged chains, but OSHA specs top rails at 42 inches, midrails, and toeboards to contain tools or grapes. Temporary doesn't mean optional; it means plan ahead with modular guardrails compliant with ANSI/ASSE Z359 standards.

Misconception 3: Sanitation Trumps Fall Protection in Washdown Areas

Food safety is king, so slippery floors from CIP systems lead some to skip guardrails, fearing bacteria traps. But 1910.28 doesn't carve out exceptions for hygiene. Properly designed stainless steel guardrails with smooth welds and sloped tops shed water and sanitize easily.

I've advised beverage giants on hybrid systems: electropolished rails meeting both OSHA and FDA 21 CFR 110. Portable nets or personal fall arrest harnesses bridge gaps during deep cleans. Prioritize both—OSHA citations hit $15,000+ per violation, and that's before insurance hikes.

Misconception 4: Low-Slope Roofs and Silos Don't Require Protection

Sloped roofs over storage silos or low-pitch warehouse additions? Many think they're safe without edges. 1910.28(b)(13) covers fixed ladders and roofs: if walking-working surfaces exist, protect edges 4+ feet up, and use warning lines or PFAS on low-slope roofs during work.

In grain processing, I've seen crews harvest from silo catwalks sans harnesses, assuming the slope prevents falls. Reality: slips from dust or condensation send workers 20 feet down. Reference OSHA's Directive STD 03-11-002 for roof work nuances; it's not optional.

• Low-slope: Warning lines 6 feet from edge.
• Steep roofs: PFAS or covers mandatory.

Misconception 5: Existing Structures Are Grandfathered In

Pre-2017 installs spark the most debates. The final rule phased in inspections but not exemptions—dangerous walking-working surfaces must be fixed regardless of install date. 1910.28(d) requires annual checks for deterioration.

We retrofitted a dairy's 1980s mezzanine after an near-miss; rusted rails crumbled under inspection. No grandfathering: if it fails load tests (200 lbs top rail), replace it. OSHA's eTool on walking-working surfaces offers free checklists—use them.

These misconceptions about 29 CFR 1910.28 fall protection cost lives and dollars in food and beverage production. Conduct gap assessments now, train per 1910.30, and document. For deeper dives, OSHA's full standard and compliance assistance resources are gold. Stay elevated, stay safe.