Monday, September 2, 2013

OSHA's Fall Protection Requirements for Aerial Lifts


When I first set down and began drafting this month’s blog post, I started off with the intent to address the many different fall protection requirements for general industry and construction. But I decided to shift gears (don’t worry, I’ll cover the general requirements in a future blog) and instead address the fall protection requirements for one specific type of equipment where I see the most misunderstandings among employers and employees: aerial lifts.
  
Federal OSHA standards 1910.67 and 1926.453 address aerial lifts for general industry and construction (respectively). Both of those contain a specific requirement that “A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift.” However, it is what the standards don’t say that can cause confusion.

During inspections of work sites, I commonly see someone working in an aerial lift wearing a full-body harness with a six-foot fall arrest lanyard attached to a tie-off point in the basket or work platform. When I ask why they are wearing that equipment, most tell me . . .
 

52 comments:

  1. Thank Curtis. As always, your clarification of OSHA standards are appreciated.

    Roger A. Hillard

    “Your OSHA Trainer”

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  2. We use a self-retracting lifeline and full-body harness on aerial lifts on my job. I feel that they are more effective at protecting the worker from hitting the surface below because of it's immediate-stop capability. What are your thoughts on this option?

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    1. SRL's require a minimum velocity to activate the brakes on most units. The problem with using them in an aerial lift is that the guardrails may act as an obstruction that slows the user's fall, allowing an employee to sustain an increased arresting force from the resulting free fall. I've had success using restraint type lanyards in aerial lifts. These are adjustable and act as a tether keeping the employee within the protections of the guardrails

      By Michael Lindsey, CSP, CHST

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  3. What about retractables for a connector in an aerial lift?

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  4. Excellent explanation of a complicated gray area. Thank you!
    Randy King

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  5. Nice article on aerial lifts. I would like to make one comment concerning scissor lifts (A92.6) used on US military projects that must comply with EM 385-1-1. After 1 OCT 2011 fall restraint and anchorage points in the scissor lift meeting ANSI Z359 are required on military projects. Even though EM 385-1-1 is a US Army Corps of Engineers document, it is adopted by the US Air Force, US Navy which included US Marine Corp projects. I made an excerpt of this requirement below.

    Van A. Howell, CSP

    /////////////////////////////////////////////////////

    DEPARTMENT OF THE ARMY EM 385-1-1

    U.S. Army Corps of Engineers

    CESO-E Washington, DC 20314-1000

    Manual No. 385-1-1 15 October 2010

    Change 2 Paragraph w.Paragraph 21.J.04, Change to read: “Elevating Work Platforms/Scissors Lifts:

    Scissors lifts shall be equipped with standard guardrails. In addition to the guardrail provided, the scissors lift shall be equipped with anchorages meeting ANSI Z359, Fall Protection Code. A restraint system shall be used in addition to guardrails. Lanyards used with the restraint system shall be sufficiently short to prohibit workers from climbing out of,or being ejected from, the platform. Scissor lifts equipped with anchorages that don’t meet ANSI Z359, Fall Protection Code may be used until 1 October 2011, at which time they must be either equipped with such anchorages or removed from service.”

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    1. Van. Thank you for sharing this information. It is important to keep up to date on all the various standards.

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    2. Is that requirement physically possible to meet? The length of a restraint that allows full access to the entire interior space of a scissor lift is too long to restrain a worker when nearest the ancorage point. That is, I don't think a standard scissor lift can ever meet military requirements.

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  6. Hey Curtis,

    I always enjoy your blogs but I think you need to clarify something in this one....? A scissors lift is an aerial lift too and does not require the tie off that a boom lift does. I recommend a restraint tie off as it is possible for a person to get launched from the scissors lift if someone runs into it or if it drops into a hole. However, I don't believe that OSHA requires a tie off in the scissors..I think you need to explain this as the general term "aerial lift" covers more than a just a boom lift. Please correct me if I am wrong.....Tim

    Tim Buford
    Safety Compliance

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    1. Tim,

      I appreciate your feedback, as well as your reading the blog. In the Aerial Lift standards of OSHA, it says it only covers boom lifts (straight and articulated) and bucket trucks. They should have called it the Boomlift and Bucket Truck section, but they didn't. While the term aerial lift is used generically to include scissor lifts, a scissor lift does not fall into the scope of this standard. That is what I was trying to explain.

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  7. Curtis,

    I appreciate the blog on clarifying fall protection for the use of “aerial lifts” on the construction side. The issue I am consistently coming across is that since OSHA has no standard specifically addressing fall protection and operation for workers on scissor-lifts for General Industry, and usually refers to their scaffold standards as well as the scissor-lift manufacturer’s instructions for safety-related information, I find my locations will not follow my policies on operation and inspection.

    Can you point out which specific OSHA Standards cover the Operation and Inspection of Aerial Lift for General Industry besides ANSI A92.2.

    Thank you, Ray

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    1. Ray.
      Thank you for your comments. Aerial lifts are covered in general industry at 1910.67. This does not include scissor lifts,. only boom-lifts, bucket trucks . . . .
      As you stated, OSHA would typically refer to the ANSI A92.6 for scissor lift requirements, as well as the manufacturer's operators manual (which usually mirrors the ANSI standard. Hope this helps, ;let me know if you have any other questions. Thanks,

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  8. This has been highly helpful and very great info. Rod

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  9. An excellent discussion of an often misunderstood topic. Thanks. BR

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  10. Curtis this couldn't have come at a better time, we have been going in circles reading the standards and kept scratching our heads. So thank you for clearing up the scissor lift requirements or should I say non-required fall protection.

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  11. I was also informed that the reason for the full body harness is in case the hydrolics go out and the bucket tilts fordward. Is this also correct?

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    1. I've never heard that as a reason to wear the equipment before, but it certainly cannot hurt..

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  12. I like the post being shared above on the aerial lifts fall protection. Fall protection is the number one thing to be considered while going for aerial lifts. One should choose the quality safety standards before performing these tasks.

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  13. If we are working at a rec center, directly over a dive pool and our subcontractor has selected a knuckle-style lift to access the ductwork that will be replaced, does OSHA require that the worker be secured at the lift? It would seem to me that it would be safer to secure to the structure above. Does OSHA allow this.

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    1. A knuckle-boom lift (aka articulating boom lift) does fall under the section for aerial lifts being discusses, so yes, the fall prevention equipment would be required in your scenario. However, the OSHA reg's do specifically prohibit tying off to structure (see 1926.453(b)(2)(iii) - "Belting off to an adjacent pole, structure, or equipment while working from an aerial lift shall not be permitted.")

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  14. Long time reader. First time commenter.

    Check out the LOI dated Feb 15, 2005. In the letter, OSHA explains (kinda) the reasoning for 453(b)(2)(iii). Essentially, they're worried about a worker connecting to a telephone pole and an out-of-control vehicle striking it. They go on to explain that if you're secured a completed structure (ie, a Certified or Non-Certified anchor as defined by Z359), this could result in a de minimis violation...at most.

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  15. great information

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  16. Great information. Can you help with a question regarding spotters for Scissorlifts. We are in a manufacturing plant that is not open to the public. Are floor spotters required when operating the lifts. Thank you

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    1. There is no specific requirement for spotters in the federal OSHA general industry standards for aerial lifts. However, check the manufacturers recommendations as well as applicable ANSI standards for further guidance.

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  17. Can you use a boom lift to get up onto a roof, if not why not? I think it would be safer than climbing a ladder. so would you have to switch fall restraint systems before exiting the boom onto the roof.

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    1. Refer to manufacturer's instruction. Many have prohibitions against this practice.

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  18. Can you use a boom lift to get up onto a roof, if not why not? I think it would be safer than climbing a ladder. so would you have to switch fall restraint systems before exiting the boom onto the roof.

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    1. Barnman. You would have to check with the manufacturer's operators manual to see if they have any specific prohibitions and/or instructions for this practice. For example, I have seen some who require the basket to be sitting firmly on the roof (or structure) before getting in or out of the basket so as to prevent application of a lateral (sideways) load that could upset the basket. And of course once you are on the roof, OSHA's fall protection standards for the work being performed would regulate what type (if any) fall protection equipment would be necessary for those workers. So check out the manufacturer's manual or call your equipment distributor/rental company. Best wishes

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  19. I have been tasked with trying to determine fall protection requirements for Electricians working in Boom Trucks involving energized lines, https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22569
    shows a section removed from the letter, but I don't know what replaces it.
    Your help would be appreciated.

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    1. It is not "replaced" by anything, you would just comply with the original requirement (tie off with a short lanyard to prevent ejection from the basket).

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  20. how can you work wearing a short restraint inside of basket, and do you need to have a shock pack on your restraint in a boom lift

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    1. Manufacturer's of lifts facilitate the use of "short" lanyards in several ways. Some install a horizontal tie-off bar that runs all the way across the basket, so when the user ties of to the bar they can slide back and forth to move around. Others install multiple tie-off points that the user can tie off to depending on were they need to be positioned. As far as shock-absorbers, a properly rigged lanyard that is going to RESTRAIN you from leaving the basket is not a fall-arrest system, so it needs no shock absorber. If, on the other hand you wear a fall arrest system with a longer lanyard that is intended to catch you after you fall out of the basket, then an absorber would be needed - HOWEVER you must make sure the lift manufacturer intends the tie-off points to be for fall arrest systems, and not for body positioning (restraint) systems. Read the manufacturers book, call you dealer . . .

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  21. Is it OK to place your foot or stand on the toe-board of an aerial lift?

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    1. Here is the applicable OSHA standard that addresses your question:

      1926.453(b)(2)(iv) - Employees shall always stand firmly on the floor of the basket, and shall not sit or climb on the edge of the basket or use planks, ladders, or other devices for a work position.

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  22. Do you have to wear fall restraints/harnesses while "tramming" the aerial lifts from one location to another. Sometime we tram across busy city streets.

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    1. Fall restraint is necessary while working in the basket of a boom-lift at any time. The purpose of the fall restraint equipment to keep you from being bounced out of the work platform/basket. This could occur when "tramming", if you ran over a curb, object . . . See the video on the link of this blog post and you can see how that happens easily.

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  23. Can you tell me, does OSHA have a standard for scissor lift training.

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    1. There is no direct standard that specifically mentions scissorlift operator training (or scissorlifts at all). However, OSHA utilizes the following generic standard for citing employers who do not ensure their operators of equipment are adequately trained . . . : "1926.20(b)(4)
      The employer shall permit only those employees qualified by training or experience to operate equipment and machinery." We offer a scissorlift operator training video / DVD lkit on our website for scissorlift operators. Hope this helps.

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  24. A bit off topic in terms of scissor lifts and the point you were trying to make, but I have been trying to find some clarification to OSHA 1926.453 (b)(2)(viii); an aerial truck shall not be moved when boom is elevated in a working position with a person in the basket, except for equipment which is specifically designed or certified as 'field modified' for this type of operation. Would you be able to let me know which type of aerial trucks (or type of work being performed) are considered certified to actually move with a person in the basket, when the boom is raised/extended? It seems to me that this would be a safety issue with the actual vehicle moving with someone in the basket. Thanks for your help in clearing my doubt.

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    1. Refer to the aerial truck manufacturer for their recommendations / restrictions for use of their trucks.

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  25. Can you use a boom lift as a tie off point when you get out of it to work on a roof?

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    1. Curtis, can you point to a reference or interpretation on using the lift as a tie off point to work on an a short overhang or vestibule? We run into this occasionally when the building GC has not supplied a railing or tie-off point. Typically we use a SRL with full body harness.

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  26. Curtis,

    Great article. I am the Fall Protection Administrator for one of the largest transit agencies in the nation and recently went thru a few days of scratching, and at times pulling the hair out of, my head over the "aerial lift fp vs scissor lift fp" issue. After reading your article, it appears that I should not revise my agency's standard to require the use of a class A SRL in scissors lifts due to your explanation about the guardrail acting as an obstruction. I'd be interested in learning more about that. Was there a specific publication or standard that you gathered this info from or was it through your own research? Any help is greatly appreciated.

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    1. The OSHA standards require all workers inside of a basket on a boom-lift to be tied off to a designated anchor point (usually provided by the lift manufacturer). The lanyard should be short as possible to prevent the worker from being catapulted out of the basket should it bounce whenever the lift runs over an object, off the edge of a surface, into a pothole, or otherwise operated in any way that could cause the basket to bounce. Because a scissor-lift is not subject to this same bouncing effect, OSHA does not have a standard requiring workers to tie off inside the work platform. Of course this assumes the worker is keeping both feet on the floor of the platform as required by OSHA, and that the guardrails are installed per the manufacturer. However, some manufacturers of scissor-lifts do install anchor points inside their platforms, and they should be used to tie off in accordance with any instructions provided by the manufacturer. An OSHA letter of interpretation on this topic is available at https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=24110&p_table=INTERPRETATIONS.

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    2. I apologize! I meant to say aerial lifts, not scissor lifts. I was referring to aerial lifts only. Hope my comment makes more sense now....

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  27. Good article, video link provides proof positive on the importance of restraining equipment while traveling. In the dummy video link to U-Tube though, I'm convinced the self retracting lanyard would have provided better protection then a fixed restraining strap while traveling. I've yet to find a self retracting lanyard that does not lock within 1 foot. The link shows the aerial lift, going full speed over 2 large bumps, dummy is not strapped in at all, self retracting lanyard would have limited movement to 1 foot, restraining strap, would allow 3-4 feet movement. Is that a fair assessment?

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    1. Hard to make a blanket statement that one type of lanyard works in all situations. A retractable lanyard may work well in a small narrow basket where the worker is limited in lateral movement, but it may result in a lanyard that is too long to keep them in a very wide basket if it is anchored in the center but the worker is several feet away. Just try and use the one that is configured so that it is the best method available for keeping your butt inside the basket!

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  28. I want to know if it is required by OSHA to have two people with lift while operating? We have a lift, and its always about safety.....

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    1. There is no OSHA standard that requires this, so check to see if the manufacturer's manual has anything that makes it necessary.

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