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Fall Protection for Aerial Work Platforms

Quick Tips #377

The use of fall protection for Aerial Work Platforms (AWP) is required by the Occupational Safety and Health Administration (OSHA). AWPs are manual or powered equipment used to provide access for people or equipment at elevation above the ground. Examples of AWPs include boom lifts (including vehicle mounted), scissor lifts, power towers, cherry or stock pickers, and bucket trucks. This document addresses unique fall protection requirements for AWPs. General fall protection standards also apply to AWPs and a summary of these standards are found in Quick Tips #130-Fall Protection Equipment, 131-Construction Fall Protection, Subpart M, and 347-ANSI Z359: A New Lift to Fall Protection Standards.

Aerial Work Platform Compliance Standards for Fall Protection

There are two industry standards for AWP compliance, the American National Standards Institute (ANSI), and OSHA. OSHA is the federal regulatory agency enforcing compliance with these standards. Complying with OSHA standards is mandatory for industries. ANSI is a body of various organizations that develop guidelines, conformity, standards and best practices for industries. Complying with ANSI standards is voluntary unless OSHA has incorporated ANSI standards by reference. However, OSHA often refers to ANSI standards for industry best practices. Therefore, OSHA may cite businesses under the “General Duty Clause” (OSHA Act of 1970, Section 5) for not following the best industry practices such as ANSI standards.

OSHA requires fall protection for AWPs under both the Construction Standards (29 CFR 1926 Subpart M) and General Industry Standards (29 CFR 1910 Subpart F). Only fall protection for boom-supported aerial lifts is directly addressed by these regulations. OSHA standard 29 CFR 1926.453(b)(2)(v) states that for boom-supported aerial lifts, “A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift.” OSHA later clarifies that, “body belts are not acceptable as part of a personal fall arrest system. The use of a body belt in a positioning system or in a restraint system is acceptable and is regulated under 1926.502(e).”

OSHA does not address fall protection for scissor lifts or other mobile lifts in these regulations, as they are not defined as an aerial lift. Scissor lift provisions can be found in the General Requirements for Scaffolds 29 CFR 1926.451.

ANSI and the Scaffold Industry Association (SIA) collaborated to develop standards for AWPs. The standards are:

These standards are based on the different types of AWPs. Fall protection requirements are mentioned in these standards and the table below provides a summary of these fall protection requirements:

ANSI Standard and AWP Type Fall Protection Requirements
ANSI A92.2 Vehicle-mounted Elevating and Rotating Aerial Devices Personal fall protection equipment is required.
ANSI A92.5 Boom-supported Elevating Work Platforms Personal fall protection equipment is required.
ANSI A92.8 Vehicle-mounted Bridge Inspection and Maintenance Devices Personal fall protection equipment may be required based on platform area and additional considerations.
ANSI A92.3 Manually Propelled Elevating Aerial Platforms If equipped, the guardrail provides fall protection.
ANSI A92.6 Self-propelled Elevating Work Platforms If equipped, the guardrail provides fall protection.

Manufacturers of AWPs may require the use personal fall protection regardless of OSHA and ANSI standards. This information should be found in the operator’s manual for the specific AWP.

Examples of Personal Fall Protection Systems for Aerial Work Platforms

A fall restraint system can be used to prevent the worker from falling or being thrown from the platform. The following type of fall protection equipment can be used for fall restraint – a short restraint lanyard, an adjustable restraint lanyard, body belt and a full body harness. However, this system prevents freedom of movement for the worker.

A fall arrest system is designed to provide freedom of movement for the worker and also provides impact or shock reduction in the event of a fall. The following type of fall protection equipment can be used for fall arrest – a shock absorbing lanyard and a full body harness. A self-retracting lifeline can be used instead of a shock absorbing lanyard and may provide a shorter free fall distance. Personal fall arrest systems should be rigged so that an employee cannot free fall more than six feet or allow the worker to come in contact with a lower surface. Determining the correct fall protection system should be based on a risk assessment and evaluated by a competent person as defined in 29 CFR 1910.66 Appendix C.

Commonly Asked Questions

Q.Can I use a body belt on an aerial work platform?

A.Yes, as long the body belt is used as part of a restraint system and the worker cannot fall more than two feet [29 CFR 1926.502(e)(1)].  For fall distances greater than two feet, a full body harness must be used as part of a fall arrest system.


Q. Does a scissor lift require fall protection?

A.If the scissor lift has a guardrail intact, then no further fall protection equipment is required (ANSI/SIA A92.3-2006 and ANSI/SIA A92.6-2006).


Q.I am using a six foot shock absorbing lanyard and a body harness for fall protection on my aerial work platform. Will this system meet OSHA’s standards for adequate fall protection?

A.It depends on the free fall distance. OSHA’s 29 CFR 1926.502d(16)(iii) requires anchorage to “be rigged such that an employee can neither free fall more than six feet, nor contact any lower level? If the anchor point prevents a free fall of less than six feet, then this fall protection system will comply with OSHA standards. If the anchor point allows more than 6 feet of free fall, then a different fall protection system must be used to comply with OSHA’s fall protection standards.


References

  1. Quick Tips # 130, Fall Protection Equipment
  2. Quick Tips # 131, Construction Fall Protection, Subpart M
  3. Quick Tips # 347, ANSI Z359: A New Lift to Fall Protection Standards
  4. 29 CFR 1926.453, Aerial Lifts
  5. 29 CFR 1926.502, Fall Protection Systems Criteria and Practices
  6. 29 CFR 1910.66, Powered Platforms for Building Maintenance
  7. OSHA’s Standard Interpretations Dated February 23, 2000
  8. OSHA’s Standard Interpretations Dated January 14, 2009
  9. ANSI/SIA A92.2-2009, Vehicle-Mounted Elevating and Rotating Aerial Devices
  10. ANSI/SIA A92.3-2006, American National Standard for Manually Propelled Elevating Aerial Platforms
  11. ANSI/SIA A92.5-2006, American National Standard Boom-Supported Elevating Work Platforms
  12. ANSI/SIA A92.6-2006, Self-Propelled Elevating Work Platforms
  13. ANSI/SIA A92.8-2006, Vehicle-Mounted Bridge Inspection and Maintenance Devices
  14. Statement of Best Practices of Personal Fall Protection Systems for Aerial Work Platform Equipment

(3/2013)


Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.

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Please Note:
The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.


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