Please Note: This is a re-post of a blog article we originally published in October of 2017. This version includes a Q&A segment at the end; these are reproductions of inquiries and responses that were generated as a result of the original article.
Are you in charge of employee safety? Then, you’re probably already aware of the importance of fall protection. Employees in both general industry and construction need fall protection at some point - particularly those who have access to aerial lifts.
But do you know the OSHA requirements for wearing fall protection when working in a lift? There have been some misconceptions about the OSHA standards. This article will help you understand what’s required so you’ll know how to comply with the regulations.
Let’s first discuss the different types of aerial lifts. The two most common types of lifts are boom lifts and scissor lifts.
A boom lift is an articulating basket. It can maneuver employees in multiple directions. These lifts are convenient for accessing hard to reach areas and tight spaces. Boom lifts are sometimes also referred to as man baskets. This is because employees work out of small work platforms enclosed with guardrails.
A scissor lift is also enclosed with guardrails, but does not articulate like a boom lift does. Scissor lifts move in a straight up and down, vertical direction only. Scissor lifts are helpful for reaching heights and areas that are easier to access.
OSHA has different requirements for fall protection in aerial lifts. It’s important to know the difference between what’s required for a boom lift and what’s required for a scissor lift.
According to OSHA standard, employees must wear “a personal fall arrest or travel restraint system” when working from a boom lift.
Why do boom lifts require the use of fall protection? This is because there is a significant risk of employees being ejected from these types of lifts. When traveling across uneven surfaces, employees can catapult out of the lifts.
Keep in mind, the type of fall protection that OSHA requires is not a personal fall arrest system. It’s a personal restraint system.
Personal fall arrest systems protect an employee who experiences a fall. The systems limit the amount of force put on the employee and prevent them from reaching the ground.
But, a fall restraint system prevents the employee from experiencing a fall at all. Think of it as “leash” system. The restraint device only allows the worker to move within a certain radius. In this case, the radius is only far enough so that they can work from within the basket. But, it’s short enough so that they’re unable to climb up or out of the basket.
There are no OSHA standards or requirements for wearing fall protection when working from a vertical scissor lift. That’s because with scissor lifts, there is no risk of catapulting out. The guardrails are enough to protect the employee from a fall hazard.
The exception to this rule comes into play when the guardrail system is “less than adequate.” This means the rails are missing, damaged, or otherwise insufficient for protecting employees.
Regardless, some scissor lifts have anchor points so that employees can properly use fall protection if desired. It’s not required. But, employees can choose to wear it so long as the lift has an ANSI-rated anchor point.
Using the Proper Equipment
What kind of fall protection equipment should your employees be using? Again, the intent is to prevent the worker from falling out of the basket. So, a fall restraint system is what they should use. This consists of either a body belt or a full body harness, and a positioning (also called 'restraint') lanyard.
Body belts are only allowed in fall restraint applications. Most employers prohibit the use of body belts altogether. This is so that employees don’t start using them improperly for other situations.
A full body harness is the preferred piece of equipment.
As for lanyards, the length is the most important factor you’ll need to consider. Remember: you want something short enough to prevent employees from climbing up and out of the basket. Adjustable length positioning lanyards typically provide the most comprehensive solutions in situations such as this.
You also want something that is practical for them to use. Make sure employees are using a positioning lanyard designed for restraint, and not a six-foot energy absorbing lanyard designed for fall arrest.
When considering anchor points, select a location approved for use in fall protection. It is NEVER okay to use guardrail as your anchor.
Discrepancies in Fall Protection Standards
There is one situation where an employee operating an aerial lift must wear a personal fall arrest system.
Is your worker using the lift to reach and access a roof or elevated work area? Then he or she needs a fall arrest system. Employees who transition from a lift to another platform face the risk of falling while climbing out of the lift and onto the other surface.
In this particular situation, employees will need to wear a “twin-legged lanyard.” This type of lanyard has two connection hooks. One attaches to the anchor point inside the lift. The other attaches to the anchor point on the roof or platform that the employee will access.
The proper way to use a twin-legged lanyard is to remain connected to the anchor point within the lift. This is true even while connecting to the new anchor point outside of the lift. This ensures “100% tie off” so that the employee is always connected to at least one anchor point.
Once the employee connects to the anchor outside of the lift, they can disconnect from the inside anchor. Employees should only connect to two anchor points during the transition period.
There is often confusion for what’s required while operating aerial lifts. That’s why, OSHA issued an interpretation letter that explains various requirements.
More Ways to Protect Your Employees
The risk of ejecting from an aerial lift is most prevalent when employees work outdoors or travel across uneven surfaces. Train your employees to do a pre-use inspection of the work area.
Things that employees should look out for include:
- Soft or wet ground
- Uneven or unstable ground
- Clutter or debris
- Weak flooring
- Grades and inclines
By avoiding these hazards, employees will significantly reduce their risk of ejection.
Questions & Answers
When using an aerial lift e.g., scissor lift, OSHA man-cage (forklift truck attachment) as a procedure or strategy to retrieve an employee who has fallen from an elevated work surface and suspended, is there a requirement to have two approved anchorages on the lift platform to accommodate the lift operator and the victim (using a spare SRL or lanyard)? In an emergency rescue procedure, when the lift motion is up and down, level grades (e.g. high bay flooring), it should be feasible to use a single anchor point. Comments?
There are no specific anchorage requirements in 1926.453 with respect to aerial lifts, although there are references in 1926.452 citing with wire rope requirements in subpart M. These would not be applicable to the question you have posed here.
In the absence of guidance in the federal regulation, I would recommend utilizing ANSI/ASSE Z359.2-2017 in forming your overall Fall Protection Program.
Z359.2, Section 188.8.131.52 states that: Anchorages selected for fall arrest systems shall have a strength capable of sustaining static loads applied in directions permitted by the system:
A. No less than 5,000 pounds for non-certified anchorages; or
B. At least two times the maximum arresting force for certified anchorages;
C. According to ANSI/ASSE Z359.6, Specifications and Design Requirements for Active Fall Protection Systems.
When more than one fall arrest system is attached to an anchorage, the strengths set forth in (A) or (B) above shall be multiplied by the number of systems attached to the anchorage.
In Section 184.108.40.206, it states that: Anchorages selected for rescue systems shall have strength capable of sustaining static loads applied in directions permitted by the system of at least:
A. 3,000 pounds for non-certified anchorages; or
B. Five times the applied load for certified anchorages.
When more than one rescue system is attached to an anchorage, the strengths set for in a (A) and (B) above shall be multiplied by the number of systems attached to the anchorage. If the anchorage is also used as an anchorage for fall arrest, it shall comply with the requirements for fall arrest anchorages indicated in this standard.
So, the short answer is this:
1. The lift platform most certainly needs to have appropriate anchorage locations. Most modern, late model equipment will be equipped with two anchorage locations.
2. Provided that the victim’s anchorage has not been compromised during the fall arrest, it may be used to accommodate the rescue device or system while the operator/rescuer utilizes the other anchorage for fall arrest purpose while facilitating the rescue.
3. If your equipment is not so equipped, I would recommend communicating with the equipment manufacturer or provider for guidance. If this is not feasible, seek the assistance of a Qualified Person or a Professional Engineer with fall protection expertise to design a rescue system and program that is appropriate for your circumstances and equipment.
We have some JLG Stock pickers models 15/20MVL 15/20MSP onsite. Can you please advise if the machine's guardrails are deemed sufficient for fall protection when operating the machine above 6', or should a fall arrest system (safety harness with anchor and decelerator or positioning device) be worn by the operator in addition to the guardrails?
Those types of aerial lifts fall more into the category of scissor lifts, as there is no articulation of the basket (meaning that the baskets only travel in an upward or downward direction). Since there is no OSHA standard that directly addresses this, the safest bet is to fall back on the recommendations from the manufacturer. If of course you feel that the guardrail is 'insufficient for protecting employees', then a fall restraint system is warranted - provided that the lift has an ANSI-rated anchor point. Common sense typically prevails in situations such as this, and it is always better to err on the side of caution. The bonus is that your employees will likely feel a greater sense of security as a result.
Do I need any type of license to operate a boom lift?
Aerial lifts are specifically addressed by OSHA at 29 CFR 1926.453 Paragraph (a) if that section requires aerial lifts to be designed and constructed in conformance with ANSI A92.2-1969 (including the appendix). The paragraph does not require the operation and use of equipment to be in conformance with the ANSI standard. The OSHA standard addressing the qualifications of lift operators is section 1926.21(b)(2), which requires employers to instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment. There are no specific OSHA regulations that require aerial lift operators to be either certified or qualified.
Can you "park" a bucket or manlift onto a roof top, then use it as an anchor for fall protection instead of setting an anchor on the roof itself?
Using a vehicle of any type as a fall protection anchor is not recommended; given that the vehicle is capable of being moved by someone other than the person attached to it. In addition, fall protection anchors must be capable of supporting a 5,000 lb. static load to be considered viable.
If you use an aerial lift as your fall protection anchor, is it acceptable to have a monitor on the ground watching the controls so no one can move the machine?
Both JLG and Genie are offering anchorage systems that affix to the top rail of their MEWP baskets, which are intended to function as anchorage locations for excursions outside of the basket. As a result, it is foreseeable that the basket could be projected above the fall hazard with a Class A SRL. It would be best to LOTO the machine, but an attendant could be utilized as well.
Wrapping it UpWe hope this article helped you understand what fall protection you need when working from aerial lifts.Avoid injuries by training your employees. They should be aware of each potential hazard of working from these types of lifts. Further, provide them with the proper fall restraint equipment. And be there to answer any questions they may have about how to use it.
Are you on the lookout for more information on fall protection use? Visit our FAQ page today! There, you’ll find some bonus tips to help get you started.