OSHA Fall Hazard Blind Spots: Openings & Maintenance Access

July 8, 2025, 12:36 pm | by Ray Nardo

The Hidden Hazards You Walk Past Every Day

Skylights, hatches, mezzanine pits. Tops of silos, tanks, or HVAC units. These areas don’t always look dangerous — until someone falls.

When it comes to fall protection in general industry, the two most overlooked categories are:

  • Openings that aren’t always open
  • Machinery maintenance access points

Both are common. Both are deadly. And both are called out clearly in OSHA and ANSI standards.

  1. Openings That Aren’t Always Open

Skylights, roof hatches, mezzanine drops, floor cutouts, and pit access points

These are deceptively dangerous areas. Whether they’re used once a month or once a day, any opening that a worker could fall through must be protected.

OSHA 29 CFR 1910.28(b)(3)(i)

“Each employee must be protected from falling through any hole (including skylights) that is 4 feet or more above a lower level by a cover or guardrail system.”

Even temporary cutouts or uncovered leveler pits during cleaning qualify under this standard.

Skylights Are NOT Safe to Stand On

They are considered holes in the walking-working surface per OSHA. If someone can fall through it, it must be protected.

Common Facility Risks:

  • Roof hatches left open during inspections
  • Floor holes cut during retrofits
  • Dock leveler service openings
  • Skylights mistaken for solid surfaces
  • Mezzanine transfer zones with no guarding
  1. Machinery Maintenance Areas

Elevated or awkward areas where technicians access equipment for inspection, service, or repair

When workers climb on top of equipment — like silos, presses, ovens, or production lines — they’re often exposed to fall risks without dedicated anchor points, guardrails, or designated access platforms.

OSHA 29 CFR 1910.23(c)

“Each employee on a walking-working surface with an unprotected side or edge that is 4 feet or more above a lower level must be protected by guardrail systems, safety nets, or personal fall protection systems.”

ANSI Z359.2 & Z359.18

  • Z359.2: Requires hazard assessments and formal procedures for elevated service tasks
  • Z359.18: Specifies structural anchorage design and use requirements for fall arrest systems around equipment and machinery

Common Maintenance Hazards:

  • Standing on top of industrial ovens, chillers, or presses
  • Climbing above ducting or piping for access
  • Walking on narrow steel beams or catwalks
  • Reaching across conveyor belts or hoppers

How FallProof Fixes the Blind Spots

Our team specializes in designing and installing turnkey fall protection systems for the areas most often missed:

 

 

For Openings:

  • Skylight safety screens (non-penetrating options available)
  • Hatch rail systems with self-closing gates
  • Custom floor hole covers that meet load rating standards

For Maintenance Access:

  • Overhead rigid tracks for SRL systems
  • Custom platforms with guardrails for safe access
  • Permanent or portable anchor points for fall arrest
  • Field assessments to pinpoint blind spots before they become incidents

📅 Schedule a facility walkthrough »

📞 Or speak directly with our safety engineering team at (609)-325-5555

Final Word

Openings and elevated maintenance zones don’t always get flagged as fall hazards — but they should.

They’re the places where workers take shortcuts, and where one slip can become a catastrophe.

Let’s make sure your facility isn’t one hazard away from a headline.

2018 Workplace Fall Fatalities by Industry

March 11, 2020, 9:47 am | by Ray Nardo

Why Fall Protection Is ImportantThis blog is brought to you by FallProof Systems to educate our clients and colleagues on the fall risks associated with different workplaces and jobs.

43% of workplace fall fatalities were in the construction industry. Injuries and illnesses from falls are considered preventable incidents that can be minimized or reduced with proper fall protection. Are you in compliance? Read more.

Lifetime of Fall Arrest Equipment

November 25, 2019, 12:00 pm | by Ray Nardo

OSHA ANSI Safety Harness Fall Protection InspectionHow many times have you gotten the question “When do I need to replace my harness”? The first thing you would do is look to ANSI Standards or OSHA Regulations for an answer. Coincidentally, they leave it up to the manufacturer to determine how long a harness or lanyard should be left in service. Read more.

Inspections of Fall Protection Systems – OSHA and ANSI Compliance

September 20, 2019, 2:28 pm | by Ray Nardo

Torn Harness Fall Protection Equipment Inspections By FallproofThis blog will be a two-part discussion on Inspections of Fall Protection Systems. This month we will cover the OSHA (Occupational Safety and Health Administration) and ANSI (American National Standards Institute) standards and how to stay in compliance according to revised Walking-Working Surface Standard which OSHA made effective by January 17, 2017. The revised OSHA Walking-Working Surface Standard along with the ANSI standard define the responsibility of the employer and employee for inspecting Fall Protection Systems in the Construction Industry and General Industry. Read more.

Leading Edge Fall Protection Equipment and Uses

August 6, 2019, 3:30 pm | by Ray Nardo

Leading Edge Steel Working Fall Protection EquipmentIn this blog we will discuss leading edges and the new self-retracting lifeline issued for leading edges.  What constitutes a leading edge, how the fall protection system and equipment is used as well as understanding OSHA and ANSI standards for leading edges can be difficult and confusing for employers and employees.  Part of the confusion stems from the different definitions OSHA and ANSI have for leading edges as well as the PFAS used by the worker to protect them from the leading edge. Read more.

A Review of the ABCs of Fall Protection

July 7, 2019, 11:49 am | by Ray Nardo

Fall Protection Basics

ABCs of Fall ProtectionWorking at heights can be challenging and difficult. The best way for workers to protect themselves is to remember the basics of fall protection systems. The basics consist of an understanding of the ABC’s of fall protection. The ABC’s of Fall Protection consist of (A) anchorage; (B)body wear, and (C) connectors and can be also known as a PFAS- personal fall arrest system. Although the basics can be boring and simplistic an understanding of them can save your life! Read more.

Anchorages – Certified Verse Non-Certified

June 3, 2019, 10:49 pm | by Ray Nardo

Selecting Fall Protection Anchorage PointsThis blog will discuss the difference between Certified and Non-Certified Anchorage. The main differences between Certified and Non-Certified Anchorage are the different categories of anchorage, the design loads for these anchorages, and who is qualified to authorize the usage of the anchor. Anchorages fall under five unique categories: Fall Arrest; Work Positioning; Travel Restraint; Horizontal Lifeline-Rigid Track; and Rescue and ANSI Z359 provides distinct loading requirements for each. The following design loads- the maximum amount of something a system is designed to handle- specified in the ANSI Z359.2-2007. Read more.

Continued Blog: Hierarchy of Fall Protection – Fall Restraint Systems

April 7, 2019, 8:58 am | by Ray Nardo

Roof Inspection Fall Restraint Systems FallProofIn this blog we will continue to discuss the hierarchy of fall protection and another way for employers to protect their workers. As previously noted, each fall risk situation should be analyzed on a case by case basis so it is important to understand the work being performed, access to the work area, and the frequency of the work. Here, we will discuss the 3rd solution on the hierarchy of fall protection pyramid- Fall Restraint Systems also known as Travel Restraint Systems.  Sometimes, Passive Fall Protection Systems- like guardrail- which was discussed in last month’s blog- is not an option and is why an employer moves to the next option on the hierarchy- a Fall Restraint System. Read more.

Continued Discussion: Hierarchy of Fall Protection – Fall Prevention Systems

February 28, 2019, 10:02 pm | by Ray Nardo

Fall Protection PyramidAs discussed in last month’s blog understanding the hierarchy of fall protection will help an employer and employees who are working at heights make their work environment as safe as possible. In this blog we will talk a little more about Fall Prevention Systems which is second on the hierarchy of fall protection. Fall Prevention Systems are second on the hierarchy because the first solution– Elimination- preventing access or removing the hazards is always the safest and best first solution. For instance, removing an air handler from the roof to the ground or replacing a ladder with a stairway are ways to eliminate the fall hazard. Ideally, the safest option to ensure worker safety is to completely eliminate the fall hazard. However, if this not possible a Fall Prevention System can be installed to create a barrier which is another way of eliminating the hazard. Read more.

Hierarchy of Fall Protection

February 4, 2019, 9:19 pm | by Ray Nardo

Fall Protection Guardrail System InstallationUnderstanding the hierarchy of fall protection is important because it allows companies to make the best possible choice in protecting their workers who are working at heights. FallProof Systems can help your company in understating this hierarchy; identify fall risks and hazards and then offer solutions. Read more.