Walking & Working Surfaces: How to Prevent Slip-and-Fall Injuries (and OSHA Fines) in Your Clinic (29 CFR § 1910.22)

Slip, trip, and fall injuries are one of the most common and expensive categories of workplace incidents in healthcare settings, and they frequently occur on ordinary floors, corridors, and exam room entrances that staff use all day. OSHA’s walking working surfaces rule at 29 CFR 1910.22 requires employers to keep these surfaces clean, dry when feasible, structurally sound, and free of recognized hazards such as leaks, spills, loose flooring, and clutter.

For a small practice, failing to comply with 1910.22 can lead to OSHA citations, workers compensation claims, lost work days, and reputational harm if staff perceive the clinic as unsafe. The regulation also intersects with the OSHA General Duty Clause, which requires employers to keep the workplace free of recognized serious hazards even when a specific rule is not detailed.

This article explains what 29 CFR 1910.22 actually requires, how OSHA evaluates walking and working surfaces during inspections, and how a lean clinic can create a practical, documented program to prevent slip and fall injuries. You will see how a few simple tools logs, photos, and checklists can demonstrate compliance and dramatically reduce the likelihood of a costly injury or citation.

Most small clinics focus their safety energy on clinical issues such as infection control, sharps handling, and PPE. However, many OSHA inspections and workers compensation claims originate from something more mundane a staff member who slips in a wet hallway, trips over a misplaced cart, or falls on a cluttered stairway. Because these events feel “ordinary,” leadership may treat them as bad luck rather than as evidence of a compliance gap under 29 CFR 1910.22.

The walking and working surfaces rule is deliberately broad. It covers any surface used for walking or work inside the clinic: floors, corridors, ramps, stairs, and even the surfaces where equipment is placed. In a small practice with limited storage, these spaces are often used for multiple purposes storage, patient flow, and staff circulation, which increases the risk of clutter and spills.

For clinics billing Medicare and commercial payers, these injuries also have indirect financial consequences. Staff out on injury leave slow down operations, and OSHA citations can trigger broader liability reviews by insurers and landlords. A documented 1910.22 program helps show that the clinic has an organized safety system, which can be valuable if an incident escalates into litigation or a regulatory inquiry.

Understanding Legal Framework & Scope Under 29 CFR 1910.22

OSHA’s general industry standard for walking and working surfaces, 29 CFR 1910.22, lays out the baseline duties that apply to small clinics just as they do to hospitals or large employers. Key elements of the rule include housekeeping, surface conditions, load bearing, access, and inspection and maintenance.

At a high level, 1910.22 requires that:

• All places of employment, passageways, storerooms, and service rooms must be kept clean, orderly, and in a sanitary condition. This is the core housekeeping obligation that applies directly to corridors, exam room hallways, and supply areas in a clinic.

• The floor of every workroom must be maintained in a clean and, so far as possible, dry condition. Where wet processes or spills occur, the employer must provide drainage or dry standing places such as raised platforms, mats, or other means.

• Walking working surfaces must be kept free of known hazards such as sharp or protruding objects, loose boards, leaks, spills, snow, and ice.

• Employers must ensure that walking working surfaces are inspected regularly and as necessary, that hazards are corrected or guarded, and that damaged areas are repaired promptly.

The OSHA General Duty Clause in the Occupational Safety and Health Act also requires employers to provide a workplace free from recognized hazards that are likely to cause death or serious physical harm. When it comes to slips and falls, this clause can be cited alongside or instead of 1910.22 if there is clear evidence that the employer knew about a hazard but failed to address it.

There is limited state flexibility here. State plan OSHA programs may add requirements or provide more detailed guidance, but they cannot reduce the protections in 1910.22. Landlords may also have responsibilities for common areas, but a clinic cannot rely on the landlord alone to manage risk. The clinic remains responsible for its own spaces and for reporting hazards in shared areas.

Understanding this framework helps a small practice design a focused program: identify walking surfaces, assign inspection responsibilities, document housekeeping practices, and maintain basic records of repairs. Done correctly, this preparation reduces not only OSHA citation risk but also the friction that follows a staff injury incident.

OSHA, within the U.S. Department of Labor, enforces 29 CFR 1910.22 in most private healthcare settings, including small medical, dental, and specialty clinics. In states with approved state plans, a state OSHA program enforces substantially similar rules.

Several triggers commonly bring walking and working surface issues to OSHA’s attention:

• Employee complaints. A staff member who repeatedly slips in a wet corridor or sees cluttered stairways may file a confidential complaint. OSHA often responds with an inquiry or on site inspection focused on the reported hazards.

• Injury and illness reports. Recordable slip and fall injuries, particularly those that require medical treatment beyond first aid or result in lost days, can draw attention during programmed inspections or follow-up visits.

• Targeted emphasis programs. OSHA periodically runs national or regional emphasis programs on hazards like falls, healthcare, or musculoskeletal injuries. During these, walking and working surfaces receive even closer scrutiny.

• Referrals from other agencies or insurers. Fire departments, workers compensation carriers, and accreditation bodies may refer obvious slip hazards to OSHA, especially if they see repeated incidents.

When inspectors evaluate walking and working surfaces in a clinic, they look for both conditions and systems. Physical conditions include wet floors, missing tiles, raised thresholds, poor lighting, unsecured cords, and blocked exits. Systems include inspection routines, maintenance logs, spill response procedures, and staff training. A small clinic that can produce simple, dated records aligned with 1910.22’s inspection and housekeeping requirements is far more likely to resolve an inquiry with minimal disruption.

Even though this heading uses HIPAA language, you can treat it as your practical playbook for surviving an OSHA review of walking and working surfaces under 29 CFR 1910.22. The focus is on low cost, high evidence controls.

1. Create a walking surface inventory tied to risk
   Start by listing the primary walking and working surfaces in your clinic entrances, reception, corridors, exam hallways, lab area, staff break room, and any stairs or ramps. For each, note typical traffic levels, presence of liquids, and any history of slips. This simple inventory shows OSHA that you have consciously applied 1910.22 to your facility rather than relying on generic policies.
   Evidence to retain: A one-page map or spreadsheet naming each area, its risk level, and inspection frequency. Update annually or when layouts change.

2. Implement and document routine inspections
   29 CFR 1910.22 requires regular and “as necessary” inspections, which in a clinic can be interpreted as a daily pre-opening walk through and more frequent checks in high risk zones such as entrances and lab areas.
   Evidence to retain: A simple checklist or digital form where designated staff initial and date each inspection, noting any hazards found and actions taken. Keep at least one year of logs to demonstrate consistency.

3. Standardize spill and contamination response
   Clinics have unique slip hazards due to body fluids, disinfectants, and cleaning solutions. Under 1910.22, surfaces should be maintained in clean and dry condition, with drainage or dry standing places where liquid processes are unavoidable.
   Evidence to retain: A short, written procedure that links spill response to both infection control and walking surface safety, with staff training records showing who has been instructed on immediate cleanup, barricading, and notification.

4. Use work orders and photos to prove timely repairs
   When a tile cracks, a transition strip lifts, or a ramp edge deteriorates, 1910.22(d) expects the employer to repair or guard the hazard promptly.
   Evidence to retain:

• Dated work orders or emails to landlords or vendors describing the hazard and requested repair.

• Before and after photos stored in a shared folder labeled by area and date.
  These records demonstrate due diligence if OSHA inspects after an injury.

5. Control cords, carts, and mobile equipment
   Many clinic slip and trip events involve power cords to diagnostic devices, rolling stools, small carts, or IV poles left in corridors. OSHA treats these as housekeeping and obstruction issues under 1910.22(a).
   Evidence to retain: A brief policy stating that cords must be routed away from walkways or secured with covers, and that carts must be parked only in designated alcoves. Supervisory spot check notes or photos can show enforcement.

6. Address entrances and exterior walkways with practical controls
   While landlords may be responsible for snow and ice removal, the clinic still has duties to protect staff and patients from recognized hazards at entrances. This aligns with 1910.22’s requirement to keep walking surfaces free of hazards such as snow and ice.
   Evidence to retain:

• Copies of service contracts for snow removal or exterior maintenance.

• Logs showing when mats are placed, when “wet floor” signs are used, and when the clinic reported exterior hazards to the landlord.

7. Tie walking surface controls to your incident investigations
   Each slip, trip, or fall should trigger a short investigation that examines whether 1910.22 controls failed or were missing.
   Evidence to retain: Incident forms that explicitly ask about floor conditions, lighting, housekeeping, and inspection status at the time of the event. Track corrective actions and link them to your inspection checklists or repair logs.

Taken together, these controls give a small practice a defensible story: we know where our walking surfaces are, we check them, we fix hazards, and we can prove it with simple records tied directly to 29 CFR 1910.22.

Case Study

A small multi-specialty clinic with 18 employees occupies the first floor of a mixed use building. Over six months, three staff members slip near the back entrance that connects the staff parking lot to the clinic corridor. Two injuries require medical treatment and result in short periods of lost work time.

The corridor floor is smooth vinyl. Staff frequently enter with wet shoes during rainy weather, and the building’s gutter drains poorly, causing water to accumulate just outside the doorway. The clinic uses a small mat just inside the entrance, but it is often saturated by midday. No one has formally documented the issue or notified the landlord in writing.

After the second injury, a staff member files a complaint with OSHA. During the inspection, the compliance officer notes the following:

• The floor near the entrance is visibly wet, with no “wet floor” signage.

• The interior mat is small and lacks a non-slip backing.

• There are no written inspection logs for walking surfaces.

• Leadership is aware of previous slip incidents but has not implemented any formal corrective actions.

OSHA cites the clinic under 29 CFR 1910.22(a) and (d) for failing to maintain walking working surfaces in a clean and dry condition when feasible, and for failing to identify and correct hazards through regular inspections. The clinic pays a monetary penalty, the workers compensation insurer increases premiums, and staff morale declines due to concerns about management’s response.

If the clinic had implemented the controls described in the playbook, the outcome would likely have been different. A walking surface inventory would have flagged the back entrance as high risk. Daily inspection logs would have documented the recurring wet condition. A simple photo series and written notice to the landlord would have shown that the clinic was actively pursuing drainage repairs and mitigating the hazard with larger mats and interim signage.

During the OSHA inspection, leadership could then have produced these records to demonstrate good faith efforts under 1910.22, shifting the focus from basic housekeeping failures to collaborative problem-solving. Even if OSHA still required improvements, penalties and reputational damage would likely have been lower, and the clinic would already have a roadmap for corrective actions.

This checklist stays tightly aligned with 29 CFR 1910.22 and gives a small practice a manageable set of tasks that can be verified quickly during an OSHA interaction.

Common Audit Pitfalls to Avoid Under 29 CFR 1910.22

To make your efforts count, it helps to know where small practices commonly stumble under the walking and working surfaces rule.

• Treating slips and trips as isolated accidents rather than as indicators of a systemic housekeeping or inspection problem, which can lead OSHA to cite 1910.22(a) and (d) for failing to maintain and inspect surfaces adequately. Practical consequence: repeated injuries and higher penalties because hazards are viewed as “recognized” and uncorrected.

• Relying on verbal routines without written inspection logs, leaving the practice unable to demonstrate “regular” inspections as envisioned by 1910.22(d). Practical consequence: during an inspection, OSHA assumes inspections did not occur and issues citations even if staff insist they “look around every morning.”

• Ignoring shared or landlord controlled areas such as parking lots, exterior steps, and lobbies, assuming they fall outside clinic responsibility. Practical consequence: OSHA may still hold the clinic accountable for not reporting hazards or mitigating risks within its control, such as interior mats and signage.

• Allowing cords, boxes, or carts to remain in corridors due to space constraints, in conflict with 1910.22(a)(1) housekeeping requirements. Practical consequence: trip hazards that are obvious to an inspector and difficult to defend.

• Failing to update controls after a slip or fall incident, which can be viewed as disregard for recognized hazards under both 1910.22 and the General Duty Clause. Practical consequence: higher penalties and a harder time disputing citations or workers compensation disputes.

By targeting these pitfalls directly, a small clinic can show OSHA that it has translated 29 CFR 1910.22 into concrete, evolving practices rather than a static policy that sits in a binder.

Walking and working surface safety is often treated as a facilities issue, but in a small practice without a facilities department, it must be woven into daily operations. The most effective approach is to designate a single safety lead, often the clinic manager who owns the 1910.22 program, supported by clear roles for front line staff.

Training should be short and frequent rather than long and rare. A brief annual orientation can explain the key ideas of 29 CFR 1910.22, while monthly safety huddles focus on current issues such as a loose threshold or chronic wet spot. Short, visual reminders placed near staff entrances can reinforce expectations about spill cleanup and corridor storage.

Simple metrics keep leadership focused. Examples include number of open work orders related to walking surfaces, percentage of daily inspection checklists completed, and number of slip incidents per quarter. Reviewing these metrics in staff or leadership meetings signals that the clinic takes 1910.22 obligations seriously.

Vendor and landlord relationships also belong in governance. Contracts for cleaning services should explicitly reference maintaining walking surfaces in compliance with OSHA standards, and the clinic should keep copies of communications to landlords about exterior hazards. These documents help demonstrate that the clinic has exercised reasonable care, even where it does not control the building infrastructure.

OSHA’s walking and working surfaces standard at 29 CFR 1910.22 is not just a housekeeping rule. For a small clinic, it is a framework for preventing one of the most common and costly categories of staff injury. By understanding the standard’s requirements for cleanliness, dry floors, hazard free surfaces, and regular inspections, a practice can design a lean, documented program that satisfies regulators and protects staff.

You do not need an elaborate safety department to comply. You need awareness of where your risks are, disciplined routines for inspecting and correcting hazards, and simple records that show OSHA you are meeting your duties. Integrating walking surface safety into incident investigations and vendor management further strengthens your position if an inspection occurs.

Immediate next steps for a small clinic might include:

1. Draft a one-page walking surface inventory and assign daily inspection responsibilities for high risk areas.

2. Create a simple inspection log and start completing it tomorrow before patients arrive.

3. Review recent incidents or near misses involving slips or trips and identify at least one corrective action tied to 1910.22.

4. Take photos of any known floor defects or chronic wet areas and initiate repair requests to landlords or vendors.

5. Add a short walking surface safety topic to your next staff meeting, reinforcing expectations about spill response and corridor storage.

Recommended compliance tool: A shared digital incident and inspection log that staff can access on existing clinic computers or tablets.
Advice: Choose one high risk corridor or entrance and implement a documented daily inspection and spill response routine this week, then expand once it is working smoothly.

• 29 CFR § 1910.22 – General requirements
  

• 29 CFR Part 1910 Subpart D – Walking-Working Surfaces
  

• 29 CFR § 1910.22 – texto en Cornell LII
  

• Walking-Working Surfaces FAQs and guidance (OSHA)