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OSHA 1917.12

Slippery working surfaces

Subpart B

14 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.12, what is the employer's basic duty about slippery working and walking surfaces in marine terminals?

The employer must eliminate, to the extent possible, conditions that cause slippery working and walking surfaces in immediate work areas used by employees. This is the plain requirement of 1917.12.

  • Elimination means taking reasonable steps to remove or correct the cause of slipperiness (for example: cleaning spills, improving drainage, applying non-skid coatings, or repairing worn surfaces).
  • If elimination is not immediately feasible, employers should use interim measures (clean-up, warnings, barriers, or temporary mats) while working toward a permanent fix.

Under 1917.12, does "to the extent possible" mean employers must make every effort even for temporary or weather-related slippery conditions?

Yes — employers must take reasonable, practical actions to remove or control slipperiness even when conditions are temporary or weather-related. 1917.12 requires elimination "to the extent possible," which means using feasible controls and reasonable measures when complete elimination is not immediately achievable.

  • Reasonable measures for temporary conditions include timely cleanup, improved drainage, anti-slip mats, temporary coverings, and warning signs.
  • Employers should document the measures they take and their plan for a permanent solution when temporary fixes are used.

Under 1917.12, can employers rely only on slip‑resistant footwear to comply with the standard?

No — employers cannot rely solely on slip‑resistant footwear when more effective elimination of the slippery condition is possible. 1917.12 requires removing the condition that causes slipperiness "to the extent possible."

  • Footwear may be used as an interim or supplemental control, but employers should prioritize eliminating the hazard at the source (cleaning, drainage, coatings, repairs).
  • If footwear is required as PPE, remember the employer payment rule for PPE applies to marine terminal settings; see the discussion in the OSHA letter on employee PPE payment methods for obligations about employer-provided PPE.

Under 1917.12, are warning signs or barricades acceptable as a control for slippery surfaces?

Yes — warning signs and barricades are acceptable interim controls, but they do not replace the employer's duty to eliminate the slippery condition when feasible. 1917.12 requires elimination "to the extent possible," so warnings are useful while permanent corrections are made.

  • Use signs or barriers immediately after discovering a slippery area to protect employees.
  • Combine warnings with cleanup, repairs, or other corrective actions so the hazard is ultimately removed.

Under 1917.12, what immediate steps should employers take after a spill that creates a slippery surface in a marine terminal work area?

Employers should promptly clean up the spill, secure the area to prevent slips, and, if needed, provide temporary measures until the surface is restored. This approach satisfies the action-oriented requirement of 1917.12 to eliminate slippery conditions "to the extent possible."

  • Immediate steps include stopping the source of the spill, using absorbents or rinsing, placing warning signs or barricades, and scheduling permanent repairs or resurfacing as needed.
  • Document cleanup actions and follow up until the hazard is eliminated.

Under 1917.12, does the standard apply to a "designated waterfront facility" used only for bulk liquids, or is it limited to marine terminals?

Part 1917 provisions, including requirements like 1917.12, do not apply to "designated waterfront facilities" used solely for bulk storage, handling, and transfer of liquids or gases; in that situation OSHA standards for marine terminals do not apply. See the Applicability to waterfront facilities letter of interpretation for details.

  • That letter explains that a "designated waterfront facility" falls within the marine terminal definition and that, in such specific situations, Part 1917's requirements may not apply.
  • If your facility is uncertain about coverage, consult the cited interpretation and your regional OSHA office for clarification.

Under 1917.12, how does an employer show compliance when a slippery condition cannot be fully eliminated immediately?

An employer shows compliance by taking timely, reasonable steps to control and correct the slippery condition and documenting those actions and plans to fully eliminate the hazard. 1917.12 requires elimination "to the extent possible," which implies active efforts and follow-through.

  • Document immediate controls (cleanup, barricades, signage), personnel assigned, timelines for permanent fixes (repairs, resurfacing), and any interim training or PPE provided.
  • Keep records of inspections and corrective actions to demonstrate diligence and progress toward elimination.

Under 1917.12, are employers expected to use engineering controls such as non‑skid surfaces or drainage to address slipperiness?

Yes — employers are expected to use feasible engineering controls like non‑skid coatings, improved drainage, or resurfacing when those measures will eliminate or meaningfully reduce slippery conditions. That approach is consistent with the elimination requirement in 1917.12.

  • Engineering controls address the hazard at its source and are generally preferred over reliance on PPE or administrative controls.
  • Implement engineering fixes when they are practical and proportionate to the hazard and workplace operations.

Under 1917.12, does the employer need to train employees about slippery surface hazards and protective measures?

Yes — while 1917.12 specifically requires elimination of slippery conditions, training employees on hazard recognition, safe work practices, and interim controls (cleanup, signage, proper footwear) supports compliance with the standard. See 1917.12.

  • Training should cover how to report spills, who will clean them, when to avoid an area, and what PPE or procedures are required as temporary protections.
  • Training records and documented refresher sessions help show the employer is actively managing the risk.

Under 1917.12, must employers remove slippery contaminants that originate on vessels when employees work on adjoining terminal walkways?

Yes — employers must eliminate slippery conditions in immediate work areas used by employees, which includes terminal walkways adjoining vessel operations when those areas are used by employees. 1917.12 requires removal of conditions causing slippery surfaces "in immediate work areas used by employees."

  • Coordinate with vessel operators as needed to control sources of contamination and clean shared walkways promptly.
  • Use temporary controls (signs, barriers) while arranging cleanup or repairs.

Under 1917.12, can administrative policies (like 'walk slowly' rules) substitute for physical elimination of slippery surfaces?

No — administrative policies alone are not an adequate substitute for eliminating slippery conditions when elimination is feasible; 1917.12 requires employers to eliminate the slippery condition "to the extent possible."

  • Administrative rules are useful as supplemental measures, but employers should correct the hazardous surface by cleaning, repairing, or applying engineering controls when reasonably practicable.
  • Combine administrative controls with physical corrections and PPE as part of a layered approach while working toward elimination.

Under 1917.12, are employers required to provide and pay for slip-resistant footwear for employees who must work in areas with unavoidable slippery surfaces?

If slip‑resistant footwear is required by the employer to protect employees, the employer must provide it and follow the employer-payment rules that apply to PPE; OSHA's guidance on PPE payment in maritime contexts explains employer obligations. The primary obligation to remove slippery surfaces remains in 1917.12.

  • The OSHA letter on employee PPE payment methods discusses employer responsibilities for paying for PPE in maritime and related standards; if footwear is required PPE, employers generally must supply it absent specific exceptions.
  • Employers should also pursue elimination or engineering controls rather than relying only on PPE.

Under 1917.12, does compliance only apply to main aisles and work platforms, or does it also cover small "immediate" work areas like around equipment?

Compliance applies to all "immediate work areas used by employees," which includes main aisles, platforms, and smaller areas around equipment where employees work. 1917.12 uses that phrasing to capture any space employees use for work or movement.

  • Inspect and correct slippery conditions wherever employees perform work tasks or travel, even if the area is small or temporary.
  • Regular housekeeping and spot inspections help identify and correct localized slippery hazards promptly.

Under 1917.12, when a terminal is modifying equipment or surfaces to reduce slipperiness, are there other Part 1917 rules about alterations to equipment to keep in mind?

Yes — while making changes to reduce slipperiness is appropriate, other Part 1917 provisions (for example those covering equipment modifications) may apply; consult the broader Part 1917 requirements at 1917.

  • For example, modifications that affect equipment safety or capacity in other contexts may require approvals or adherence to related provisions; see Part 1917 for applicable equipment rules.
  • If uncertain about a particular modification's regulatory implications, document the safety analysis and consult OSHA regional offices.