OSHA Issues Memo about Fall Protection on Aerial Lifts

On January 14, 2009, OSHA issued a letter of interpretation regarding the use of a particular shock absorbing lanyard to satisfy the requirements found in §1926.453(b)(2)(v). The Directorate of Construction has received inquiries from regional offices, area offices and the public asking if the January 2009 letter banned the lanyard in question.

OSHA did not ban the particular lanyard but stated, based on the manufacturer’s instructions, which stipulated a minimum anchor point height of 18.5 feet, it was likely that the lanyard’s use would not comply with OSHA standards at lower heights.

In such cases, use of the lanyard below 18.5 feet would apparently not provide adequate fall protection. This determination has raised questions about the use of body harnesses, typically married with appropriate lanyards, for fall protection in aerial lifts. To help avoid any confusion on the issue, DOC is rescinding the January 2009 letter, #20070823-7896.

Under subpart L, employers must ensure that employees tie off at all times when working from an aerial lift [ §1926.453(b)(2)(v)]. Employers must ensure that employees using personal fall arrest systems while working on aerial lifts at heights 6 feet or more above a lower level comply with §1926.502(d) of subpart M, specifically:

Personal fall arrest systems, when stopping a fall, shall:

(iii) be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level. [ §1926.502(d)(16)(iii)]
However, §1926.502(d) does not require employers to comply with manufacturer’s instructions when using personal fall arrest systems. To cite §1926.502(d)(16)(iii), the facts must show that the personal fall arrest system would permit a free fall of more than 6 feet or would permit contact with a lower level – and not base this conclusion solely on information provided by the manufacturer.

As has been the agency’s longstanding policy, an employer may comply with OSHA’s fall protection requirements for aerial lifts in one of three ways:

1. Use of a body belt with a tether anchored to the boom or basket (fall restraint system),
2. Use of a body harness with a tether (fall restraint system), or
3. Use of a body harness with a lanyard (fall arrest system).

About the SIA
The Scaffold Industry Association (SIA) is a non-profit trade 501(c)(6) association committed to raising the standards of professionalism within the scaffold and access industry. The SIA represents all facets of the scaffold & access industry through various councils that include, aerial work platform, construction hoist, fall protection equipment, international, industrial, mast climbing, plank and platform, supported scaffold and suspended scaffold. Through its various programs, the SIA promotes safety, training and a highly professional, responsible image of the scaffold and access professional. The SIA delivers hundreds of safety training programs a year at various locations throughout the world. These programs cover all aspects of scaffold and access safety and equipment use. The SIA is also the secretariat for the American National Standard, ASC A92 standards. For more information, call (816) 595.4860 or visit them at www.scaffold.org.