When OSHA §1910.22 Does Not Apply in Transportation and Trucking

OSHA's regulation §1910.22, 'Walking-Working Surfaces,' sets out standards for aisles, stairways, walkways, and crawlways to ensure safety in the workplace. However, its application in the transportation and trucking industry can be nuanced. Let's dive into when this regulation might not apply or fall short.

Exemptions in Transportation and Trucking

The transportation and trucking sectors often operate under different conditions than traditional workplaces. Here are scenarios where §1910.22 might not fully apply:

• Mobile Work Environments: In trucking, the primary workplace is often a moving vehicle. The dynamic nature of these environments can make it challenging to maintain the same standards as static workplaces.
• Loading and Unloading: During the loading and unloading of goods, the temporary nature of the work can mean that permanent safety measures like those outlined in §1910.22 are impractical or not applicable.
• Outdoor Operations: Many transportation activities occur outdoors, where weather conditions can affect the feasibility of maintaining the standards set by §1910.22.

Limitations of §1910.22 in Transportation

While §1910.22 provides a solid foundation for safety in many industries, it has limitations when applied to transportation and trucking:

• Vehicle-Specific Hazards: The regulation does not address hazards unique to vehicles, such as the risk of falling from a truck bed or the dangers associated with securing loads.
• Temporary Structures: The use of temporary ramps, docks, and other structures during loading and unloading operations often falls outside the scope of §1910.22.
• Regulatory Overlap: Other regulations, such as those from the Department of Transportation (DOT), may supersede or complement §1910.22, leading to potential confusion or gaps in coverage.

Best Practices for Safety in Transportation

Given the limitations of §1910.22, here are some best practices to ensure safety in the transportation and trucking industry:

• Regular Training: Conduct ongoing safety training tailored to the specific hazards of the transportation environment.
• Custom Safety Protocols: Develop safety protocols that address the unique challenges of mobile and outdoor workspaces.
• Collaboration with DOT: Work closely with DOT regulations to ensure comprehensive safety coverage.

In my experience, the key to safety in transportation is flexibility and adaptability. We've seen that while §1910.22 provides a strong baseline, the dynamic nature of trucking requires additional measures. Based on available research, individual results may vary, but integrating these best practices can significantly enhance safety in your operations.