Aerial Lifts Personal Fall Protection Requirements

| OSHA, USF Safety Florida

Written by Noel McCatty Jr., USF SafetyFlorida Safety Consultant

When job tasks take place in hard-to-reach areas or unfinished environments, aerial lifts are often the answer. Aerial lifts have replaced ladders and scaffolding on many job sites due to their mobility and flexibility. They may be made of metal or fiberglass reinforced plastic and can be powered or manually operated, usually equipped with vertical rotating capabilities. OSHA’s Vehicle-Mounted Elevating and Rotating Work Platforms Standard (29 CFR 1910.67) utilizes the American National Standard Institute Standard (ANSI A92.2-1969), in classifying aerial devices. It goes on to further define a vehicle as “any carrier that is not manually propelled.” These include but are not limited to:

  • Extendable boom platforms
  • Aerial ladders,
  • Articulating (jointed) boom platforms,
  • Vertical towers, and
  • Any combination of the above.

To better understand the intent of the standard, we must look at 29 CFR 1910.67 for General Industry, more specifically  1910.67(c)(2)(v):

A personal fall, arrest or travel restraint system that meets the requirements in Subpart I of this part shall be worn and attached to the boom or basket when working from an aerial lift.

Workers must wear a personal fall arrest or travel restraint system that meets the requirements of 29 CFR 1910 Subpart I and attach it to the boom or basket when working from an aerial lift such as a cherry picker. In a Letter of Interpretation dated March 22, 1976, OSHA clarified the use of the word “from” does not imply that employees are exempt from wearing fall protection when working on an aerial lift. The LOI reads as follows:

“A review of both general industry and the construction standards support this interpretation by stating: ‘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.’

To maintain compliance with this standard, employers are encouraged to require employees operating aerial lifts:

  • Ensure that access gates or openings are closed
  • Stand firmly on the floor of the bucket or lift platform.
  • Not climb on or lean over guardrails or handrails.
  • Not use planks, ladders, or other devices as a working position.
  • Use a body harness or a restraining belt with a lanyard attached to the boom or bucket.
  • Do not belt-off to adjacent structures or poles while in the bucket.

Many workers are injured or killed on aerial lifts each year. Whether your job is located on a construction site or in a general industry setting, a fall from an elevated platform can result in significant injury or death. Before you begin to assess the risks and identify the potential hazards, you must first evaluate your level of expertise. The USF Safety Consultation Program is here to help. Our team of experts has over 150 years of combined occupational safety and health experience and stands ready to help small employers in identifying and eliminating hazards at the workplace. To access OSHA’s scaffolding eTool, visit https://www.osha.gov/SLTC/etools/scaffolding/index.html. For a confidential, no-cost consultation, please visit our website usfsafetyflorida.com or call 866-273-1105.

Noel McCatty, Jr.

Safety Consultant

USF SafetyFlorida Consultation Program