ISO 45001 Slips, Trips and Falls in Food Processing Plants

Food processing plants are built to be washed. Hoses, caustic foamers, sanitizer, condensate, brine and product fat all end up on the floor by design, and the people working in those rooms are expected to move quickly, carry product, and stay on their feet for ten hours. I have come to think that slips, trips and falls are the clearest test of whether a food plant's safety system is real, because the hazard is everywhere, it is mundane, and nobody can point to a single dramatic event that forces action. It just accumulates, one near miss and one sprained ankle at a time.

This guide covers how to manage slips, trips and falls in a food plant using ISO 45001:2018 as the management framework, with the OSHA walking-working surfaces rule in 29 CFR Part 1910, Subpart D as the legal floor. If you are new to the standard, what ISO 45001 is and how it is structured is a good place to start before coming back here.

Why do food processing plants have such a persistent slip, trip and fall problem?

Because the conditions that create the hazard are the same conditions that keep the product safe. Sanitation under 21 CFR Part 117 (the FDA's current good manufacturing practice and preventive controls rule for human food) requires frequent cleaning of the plant and food-contact surfaces. Wet cleaning puts water and chemicals on floors. Cold rooms produce condensation and ice. Cooking, frying and rendering put grease and fat on surfaces. Washdown means drains, hoses and floor trenches. Add pallets, hoses, conveyors and product carts in tight aisles, and you have all three failure modes at once.

It helps to separate them, because the controls differ:

• Slips happen when there is not enough friction between the shoe and the floor. Liquids, fats, product residue, and worn or sealed-smooth flooring are the usual causes.
• Trips happen when a foot hits something that should not be there: hoses, drain covers, floor-mounted conveyor frames, uneven expansion joints, pallets, loose mats, and raised thresholds between rooms.
• Falls include falls on the same level after a slip or trip, and falls from height off stairs, platforms, mezzanines, tank tops, ladders, and loading dock edges.

A plant that treats all three as "housekeeping" will keep having all three.

What does OSHA actually require for walking-working surfaces?

The legal baseline is 29 CFR 1910.22, which applies to all places of employment. In plain terms it requires that walking-working surfaces be kept clean, orderly and sanitary, and that floors be maintained in a clean and, to the extent feasible, dry condition. For operations that are inherently wet, 1910.22(a)(3) goes further: where wet processes are used, drainage must be maintained and, to the extent feasible, dry standing places such as false floors, platforms and mats must be provided. That sentence was written for plants like yours.

Under 1910.22(a)(4), surfaces must also be kept free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow and ice, and under 1910.22(d) they must be inspected regularly and as necessary and maintained in a safe condition. For falls from height, 29 CFR 1910.28(b)(1) sets a general four-foot trigger for protection from unprotected sides and edges in general industry, with specific provisions elsewhere in 1910.28(b) for situations such as hoist areas and holes. Loading dock edges have their own provision in 1910.28(b)(3). 1910.23 and 1910.25 cover ladders and stairways. The rule was revised in a final rule that took effect in January 2017, so if your fall protection thinking dates from before that, it is worth a second look.

OSHA's requirement is a floor, not a program. Nothing in 1910.22 tells you how to find the hazards in your plant, who owns them, how fast they get fixed, or how you know the fix worked. That is what ISO 45001 supplies.

How does ISO 45001 change the way you manage slips, trips and falls?

It moves you from reacting to floor incidents toward a system that finds, ranks and removes the hazards before someone is hurt. The clauses that matter most for this topic are these:

The clause I would underline is 8.1.2, because it lists the hierarchy in a specific order: eliminate the hazard, substitute less hazardous processes or materials, use engineering controls and reorganization of work, use administrative controls including training, and finally provide adequate personal protective equipment. A common pattern is to start at the bottom of that list, with a wet floor sign and a footwear policy, and then wonder why the numbers do not move.

How do you identify slip, trip and fall hazards in a food plant?

Walk it the way the work is actually done, at the time it is actually done. A floor that looks fine at 7:00 a.m. on a dry shift is a different floor at 2:00 a.m. in the middle of the washdown. Clause 6.1.2.1 explicitly asks for routine and non-routine activities, and sanitation, changeover and maintenance are exactly the non-routine work that drives injuries.

A useful approach is to combine three methods. First, a zone-by-zone floor survey that records the surface type, the condition, the liquid source, the drainage, and the footwear in use. Second, a task-based review such as a job hazard analysis for the highest-risk tasks. Third, structured worker input, because the person who has pushed a cart across that doorway for six years knows more than any consultant. For a wider look at methods, see our hazard identification guidance.

Here is a starting map of where the hazards tend to sit:

What does the hierarchy of controls look like for a wet floor?

This is where I think most food plants either get serious or get stuck. Here is the same hazard, a wet floor in a processing room, worked through clause 8.1.2.

None of this is meant to dismiss footwear. Good slip-resistant boots matter, and a program that checks tread wear and replaces boots on a schedule is worth having. But footwear is the last item on the hierarchy for a reason. If your whole slip program is boots and signs, you have told the worker that the floor is their problem.

A point that surprises people is how often food safety and worker safety pull against each other. A rough, aggressive flooring finish may grip better but can be harder to clean, which creates a sanitation concern under 21 CFR Part 117. A good ISO 45001 system forces those two functions into the same room early. The answer is usually a flooring specification that both quality and safety have signed, not a fight after the floor is poured.

How do you handle change, contractors and temporary workers?

Many of the worst slip events I have reviewed trace back to a change nobody assessed. A new washdown nozzle that doubles the flow, a different foaming chemical that leaves a film, a relocated conveyor that puts a hose across an aisle. Clause 8.1.3 requires processes to implement and control planned temporary and permanent changes that affect OH&S performance. A short form that asks "what does this do to the floor?" on every equipment, chemical, layout and cleaning-method change is a cheap and effective control.

Contractors and temporary labor deserve their own attention under clause 8.1.4. Night sanitation crews are often contracted, often new, and often working in the wettest conditions in the plant. If your site orientation, footwear expectations and spill rules do not reach them, you have a gap that no amount of internal training will close. Competence evidence under clause 7.2 should cover them too, and the kinds of training records auditors expect to see apply to anyone doing work under your control.

How should you measure whether the program is working?

Clause 9.1.1 requires you to determine what needs to be monitored and measured, and how. Lagging indicators alone, such as recordable slip and fall cases, will tell you the story after the fact and are noisy in a small plant where one injury changes the year. I would pair them with leading indicators that the floor crew and supervisors can influence:

• Percentage of scheduled floor inspection rounds completed and the number of defects found per round
• Time from a reported floor defect (a failed drain, a worn mat, a leaking line) to closure
• Slip, trip and near-miss reports per hundred workers, where a rising number often means better reporting rather than a worse floor (there is no accepted external benchmark, so trend your own baseline rather than compare against other plants)
• Footwear checks completed against plan
• Number of changes reviewed for floor impact under clause 8.1.3

If you want to rank areas objectively, a simple likelihood and severity matrix works well, and building an ISO 45001 risk assessment matrix from scratch walks through one. Friction testing with a tribometer on key walking surfaces can also add objective data, particularly when you compare flooring before and after a repair or when you evaluate a new coating. OSHA sets no friction threshold for walking-working surfaces, so choose a recognized test method, apply it consistently, and set your own action level based on your baseline results.

What should happen after a slip or fall?

Clause 10.2 requires you to react to the incident, evaluate the need for action to eliminate the root causes, review and implement what is needed, and review the effectiveness of the action. In practice that means asking why, not just who. "Employee slipped on water" is not a root cause. "The drain at station 4 backs up whenever the line behind it is rinsed, and the nearest hose reel is on the far wall" is. The first produces a reminder to watch your step. The second produces a plumbing fix.

Worker participation is a requirement under clause 5.4, and the people who walk that floor should be part of the investigation team. Our post on worker participation under clause 5.4 explains what auditors look for.

What do certification auditors look for on a food plant floor?

In my experience, they look at the connection between the paperwork and the room. They will ask to see the hazard identification for sanitation, then walk the sanitation area to see whether the controls described actually exist. They will ask a floor worker where to report a slippery spot and what happened last time. They will pick a recent slip or fall and read the corrective action to see whether it addressed a cause or just a symptom. And they will check whether the legal requirements you identified under clause 6.1.3 include 29 CFR 1910.22 and the fall protection provisions that apply to your platforms and ladders. The broader planning logic is covered in Clause 6.1 planning for risks, opportunities and legal requirements.

A well-built program reads the same in the binder and on the floor. If the binder says drains are inspected weekly and the drain by the packaging line has been clogged for a month, that is the finding.

A practical 90-day starting plan

If you are building this from a standing start, here is one workable sequence:

1. Weeks 1 to 2: Walk every zone on every shift type, including washdown. Photograph surfaces, drains, thresholds and stairs. Interview workers and supervisors about where people slip and trip.
2. Weeks 3 to 4: Build the hazard register under clause 6.1.2 and rank the areas. Pull the last three years of slip, trip and fall incidents and near misses and tag them to the register.
3. Weeks 5 to 8: Fix the cheap, high-impact items first: drain maintenance, hose management, mat replacement, threshold repairs, door and seal repairs. At the same time, scope the engineering projects such as flooring, slope correction and platform protection, and get food safety and quality to co-sign the specifications.
4. Weeks 9 to 12: Launch the inspection rounds, spill response procedure and footwear program, bring contractors into scope, add the floor-impact question to your management of change form, and set the leading indicators.

Then keep it alive through internal audit (clause 9.2) and management review (clause 9.3), where slip, trip and fall performance should be an agenda item with real numbers.

Next-step checklist

A wet food plant will never have a perfectly dry floor. The goal is a plant where the water goes where it is supposed to, the walkways are clear, the stairs and platforms are protected, and someone fixes the cause when something goes wrong. To start:

• [ ] Ask floor workers on each shift where they are most afraid of slipping, and record the answers.
• [ ] Confirm 29 CFR 1910.22, 1910.23, 1910.25 and 1910.28 are in your legal requirements register (clause 6.1.3).
• [ ] Add slip, trip and fall hazards for sanitation, changeover and maintenance to your hazard register (clause 6.1.2).
• [ ] Review your last three years of floor incidents for root cause, not just the recordable cases (clause 10.2).
• [ ] Confirm your incident procedure covers OSHA 300 recording and 24-hour reporting of in-patient hospitalization.
• [ ] Add the floor-impact question to your management of change form (clause 8.1.3).
• [ ] Put slip, trip and fall performance on the next management review agenda (clause 9.3).

If you want help applying this to your own facility, you can reach out through the contact page or learn more about implementation support.

Jared Clark, JD, MBA, PMP, CMQ-OE, CQA, CPGP, RAC, Principal Consultant at Certify Consulting (https://certify.consulting)

Last updated: 2026-10-08

Frequently Asked Questions

Does ISO 45001 require specific slip resistance values for food plant floors?

No. ISO 45001:2018 is a management system standard and does not set friction values. It requires you to identify hazards (clause 6.1.2.1), assess risks (6.1.2.2), and apply the hierarchy of controls (8.1.2). Your legal baseline is 29 CFR 1910.22, which requires floors to be kept clean and, to the extent feasible, dry, with drainage and dry standing places in wet-process areas.

What does OSHA require for floors in wet processing areas?

Under 29 CFR 1910.22(a)(2), floors must be maintained clean and, to the extent feasible, dry. Where wet processes are used, drainage must be maintained and, to the extent feasible, dry standing places such as false floors, platforms and mats must be provided.

Is slip-resistant footwear enough to control slips in a food plant?

No. Under ISO 45001 clause 8.1.2, PPE is the last level of the hierarchy of controls. Footwear should support, not replace, eliminating liquid sources, fixing drainage and slope, improving flooring and managing hoses and walkways.

Which ISO 45001 clauses matter most for slips, trips and falls?

Clauses 6.1.2 (hazard identification and risk assessment), 8.1.2 (hierarchy of controls), 8.1.3 (management of change), 8.1.4 (contractors), 9.1.1 (monitoring and measurement) and 10.2 (incident and corrective action) do most of the work, supported by clause 5.4 on worker consultation and participation.

How should a food plant investigate a slip or fall incident?

Use clause 10.2: react to the incident, determine root causes, implement corrective action, and verify effectiveness. Include affected workers in the investigation under clause 5.4, and look for system causes such as drainage, hose layout, flooring or an unreviewed change instead of stopping at worker behavior.