Fall protection is an important issue for those who use aerial work platforms (AWPs). The issue facing users is determining the appropriate fall protection system or systems to use. This document addresses the unique fall protection requirements for AWPs.
AWPs are manual or powered equipment used to provide access for people or equipment at elevations above the ground. Examples of AWPs include boom lifts (including vehicle mounted), power towers, cherry or stock pickers, and bucket trucks. There are four general classes of AWPs:
- Class I: Vehicle-Mounted Elevating and Rotating Aerial Devices:
Characterized by a ladder, articulating boom or extendible boom mounted to a vehicle.
- Class II: Manually Propelled Elevating Aerial Platform:
Characterized by an elevating platform on a vertical axis mounted to a stationary base.
- Class III: Boom-Supported Elevating Aerial Platform:
Characterized by a platform supported by an extendible or articulating boom attached to a mobile or permanent base.
- Class IV: Self-Propelled Elevating Work Platform:
Characterized by an elevating platform on a vertical axis on a self-propelled base.
Aerial Work Platform Compliance Standards for Fall Protection
Both the Occupational Safety and Health Administration (OSHA) and the American National Standards Institute (ANSI) have standards and regulations that address AWP fall protection. OSHA is the federal regulatory agency enforcing compliance. ANSI develops recommendations in the form of guidelines, standards and best practices for industries. Complying with ANSI standards is not expressly mandated by OSHA unless OSHA incorporated ANSI standards by reference. However, OSHA often refers to ANSI standards for industry best practices and may cite businesses for violations under the “General Duty Clause” (OSH Act of 1970, Section 5) for not following the best industry practices.
OSHA requires fall protection for AWPs under both the Construction standards (29 Code of Federal Regulations (CFR) 1926 Subpart M) and General Industry standards (29 CFR 1910 Subpart F). Only fall protection for boom-supported aerial lifts (Class I and III) 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 clarified 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 addressed fall protection for Class II and IV AWPs in an interpretation letter dated July 21, 1998. In the letter OSHA states that the operator need only be protected by a standard guardrail that meets OSHA specifications. Fall protection would be required if the guardrail does not meet OSHA specifications or if the worker leaves the safety of the work platform, typically leaning over the railing and placing their center of balance beyond the guardrail.
The Scaffold and Access Industry Association (SAIA) serves as the secretariat for the ANSI/SAIA AWPs standards. Secretariats form committees that develop and maintain the standard(s), ensure that the process of revision is timely and in accordance with ANSI procedures, and publish the final products.
The ANSI/SAIA AWPs standards are:
ANSI and the Scaffold Industry Association (SIA) collaborated to develop standards for AWPs. The standards are:
- ANSI/SAIA A92.2-2015, American National Standard for Vehicle-Mounted Elevating and Rotating Aerial Devices (Class I)
- ANSI/SAIA A92.3-2006 (R2014), American National Standard for Manually Propelled Elevating Aerial Platforms (Class II)
- ANSI/SAIA A92.5-2006 (R2014), American National Standard Boom-Supported Elevating Work Platforms (Class III)
- ANSI/SAIA A92.6-2006 (R2014), American National Standard for Self-Propelled Elevating Work Platforms (Class IV)
- ANSI/SIA A92.8-2012, Vehicle-Mounted Bridge Inspection and Maintenance Devices (Class I)
Fall protection requirements are mentioned in each of these standards and the table below provides a summary of the 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 A92.3 Manually Propelled Elevating Aerial Platforms||The guardrail provides fall protection— additional personal fall protection equipment is not required unless any component of the guardrail is not in place|
|ANSI A92.5 Boom-Supported Elevating Work Platforms||Personal fall protection equipment is required|
|ANSI A92.6 Self-Propelled Elevating Work Platforms||The guardrail provides fall protection—additional personal fall protection equipment is not required unless any component of the guardrail is not in place|
|ANSI A92.8 Vehicle-Mounted Bridge Inspection and Maintenance Devices||Personal fall protection equipment may be required based on platform area and additional considerations|
Manufacturers of AWPs may require the use of personal fall protection regardless of OSHA and ANSI standards. This information is provided in the operator’s manual for the specific AWP.
Examples of Personal Fall Protection Systems for Aerial Work Platforms
Questions surrounding selection of an AWP fall protection system were brought into focus in January 2009 when OSHA issued a letter of interpretation regarding the fall protection equipment manufacturer-stipulated minimum anchor point elevation of 18_ feet. The fall arrest system referred to in the question included a 6-foot lanyard with shock absorber and full-body harness. The specific question was: “Since at times the distance between a lift’s work platform and a lower level will be less than 18_ feet, does the [fall protection equipment] manufacturer’s instruction regarding the minimum anchor point elevation preclude its use as part of a fall protection system in an aerial lift?” The answer from OSHA refers to 29 CFR 1926.502d(16)(iii) which requires anchorages to “be rigged such that an employee can neither free fall more than six feet, nor contact any lower level.” According to OSHA, use of the system with a six-foot shock-absorbing lanyard would not be allowed in this application.
Fall restraint and fall arrest are two categories of fall protection used on AWPs.
A fall restraint system can be used to help 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 or adjustable restraint lanyard and a body belt or a full-body harness. However, this system prevents freedom of movement for the worker.
A fall arrest system is used to minimize the distances and consequences of a fall should one occur. They are designed to provide freedom of movement for the worker. The following type of fall protection equipment can be used for fall arrest on an AWP: a self-retracting lifeline and a full body harness. Personal fall arrest systems must 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. There are several fall clearance calculators that can be used to determine the safe fall distance.
Commonly Asked Questions
Q. Can I use a body belt on an aerial work platform?
A. Yes, as long as 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. Can any self-retracting lifeline be used with AWP equipment?
A. The selected self-retracted lifeline must be one that the manufacturer has approved for use with the specific AWP equipment. Some self-retracting lifelines are not designed to have the anchorage point below the connection point on the wearer.
Q. Can the AWP guardrails be used as an anchorage point?
A. The guardrails should not be used as an anchorage point unless they have been specifically designed to do so by the AWP manufacturer and instructions for use have been supplied in the operator’s manual.
- Fall Protection Equipment
- Construction Fall Protection, Subpart M
- ANSI Z359: A New Lift to Fall Protection Standards
- 29 CFR 1926.453, Aerial Lifts
- 29 CFR 1926.502, Fall Protection Systems Criteria and Practices
- 29 CFR 1910.66, Powered Platforms for Building Maintenance
- OSHA’s Standard Interpretation Dated July 21, 1998
- OSHA’s Standard Interpretation Dated January 14, 2009
- ANSI/SAIA A92.2-2015, American National Standard for Vehicle-Mounted Elevating and Rotating Aerial Devices
- ANSI/SAIA A92.3-2006 R(2014), American National Standard for Manually Propelled Elevating Aerial Platforms
- ANSI/SAIA A92.5-2006 (R2014), American National Standard Boom-Supported Elevating Work Platforms
- ANSI/SAIA A92.6-2006 R(2014), American National Standard for Self-Propelled Elevating Work Platforms
- ANSI/SIA A92.8-2012, Vehicle-Mounted Bridge Inspection and Maintenance Devices
- Statement of Best Practices of Personal Fall Protection Systems for Aerial Work Platform Equipment