Follow-Up on Fall Protection

Katie Parrish

February 10, 2006 — In the last issue of Lift and Access 360, I had asked for input on a question a reader had posed: Is using a boom lift as an anchor point outside the platform safe? Through our research, we could not find a definitive answer, and I had hoped to create a channel of communication on the subject. A broad range of industry professionals contacted me, all eager to discuss the subject. Here are some of the highlights from the e-mails and phone calls I received.

 

In my area of expertise (construction safety), I continually encounter individuals who have not received proper or qualified training; employers who rely on the person delivering the aerial lift to the project to "train" the user; and safety people who have never read the manufacturer's manual or the applicable ANSI standard.

To comment on the issue about allowing individuals to use the aerial lift as an anchorage point when they work outside of the work platform, it is my opinion that it should not be done unless there is written permission obtained for the aerial lift manufacturers and the lift manufacturers have received specific work site conditions for the use of an aerial lift being used as an anchorage point when outside the work platform by the employer's qualified competent person.

OSHA establishes the minimum safety and health criteria. In some of the OSHA Subparts, they refer to following the manufacturer's requirements and/or the applicable ASME and/or ANSI standards. Please keep in mind that OSHA has been enforcing safety and health regulations since 1971. For the past 10 to 15 years, falls have been one of the top four causes of injuries and fatalities in the construction industry.

Better qualified training, periodic refresher training, and following the manufacturer's requirements, ANSI standards, and OSHA regulations will reduce the number of fatalities and serious injuries in the workplace. IPAF and AWPT are two organizations that are working diligently to improve training and educated aerial platform users.

These comments and opinions are based on my experience in the safety field since 1971, field safety audits, and referring to manufacturer's standards, ANSI and ASME standards and the OSHA regulations. Below are some specific comments related ANSI A92.5 standard for Boom Supported Elevating Work Platforms (aerial lifts). Section 4 briefly covers Access and Attachment Points (4.11.4 and 4.11.5).

Section 4.11.4 Access: "The aerial platform shall include access for personnel to use in reaching the platform when it is in the lowered position."

 

This could be interpreted that access in and out of the work platform is when the platform is in the lowered position. Is the lowered position the ground or other support surface?

Section 4.11.5 Attachment Point(s): "Attachment point(s) shall be provided for fall protection devices for personnel occupying the platform".

 

Fall protection is a general category that includes, but is not limited to, fall arrest, fall restraint, and work positioning. The requirement for the specific type of fall protection to be used in an aerial lift is at the discretion of the aerial lift manufacturers and the employer's competent person for fall protection.

Section 4.17 Proof Test: "Each production aerial platform shall be tested and shall sustain a test load equal to 150% of the rated work load, on level ground, to verify its integrity. The manufacturer shall determine the most critical configuration(s) of the aerial platform for this test. The test load shall be placed in the most adverse location with its center of gravity 12 inches inboard from the guardrail or in the center of the platform, whichever is less. The aerial platform shall remain stable during this test. A visual inspection shall be made to determine whether this test has produced an adverse effect on any component."

 

Using this statement, proof load testing is done within the work platform confines, not by a body falling over the guardrails and ending up outside the platform. The aerial lift manufacturers also impose a restricted and unrestricted capacity based on the load, weight, or force being inside the work platform, not falling over the guardrail and hanging outside the platform.

COMMENT: The fall protection standard states that the strength of the anchorage must be able to support without failure 5,000 pounds per individual attached to the anchorage, or 3,600 pounds if the anchorage is engineered or have a 2:1 safety factor. The Maximum Arresting Force on a human's body cannot exceed 1,800 pounds. In most of the larger aerial platforms, the manufacturer allows a 500-pound unrestricted weight or a 1,000-pound weight restriction that is based on the length of the boom arm and the location of the work platform (close to the base unit or farther away from the base unit).

Section 6.14 Modifications: "Modification or alteration of an aerial platform shall be made only with prior written permission of the manufacturer".

 

Use of fall arrest equipment that will allow a worker to fall outside of the work platform could be considered a modification or alteration to the manufacturer's original design, engineering and testing procedures.

Section 7.11.6 Capacity Limitation: "Rated capacities shall not be exceeded when loads are transferred to the platform at any height."

 

Refer to my COMMENT section for allowable forces on a human's body when following the OSHA and ANSI Z359.1 standards.

Section 7.17 Manufacturer's Safety Bulletins: "The user shall comply with safety related bulletins as received from the manufacturer, dealer, or owner."

 

If a person uses fall arrest, which allows the person to fall outside of the work platform and place a side force or eccentric force on the outside of the work platform, the manufacturer is the entity that determines if that is acceptable since the manufacturer designed, engineered and tested the piece of equipment.

Section 8.10.1: "Personnel shall maintain a firm footing on the platform floor while working therein. Use of planks, ladders, or any other devices on the aerial platform for achieving additional height or reach shall be prohibited."

 

One can reasonably interpret this section to mean that the user has to stay in the work platform and not be able to fall over the side, which would be considered "achieving additional height or reach."

 

Bob Harrell

Safety Management Services

San Diego, Calif.

 

Regarding your article “Open Dialogue for Fall Protection,” this is exactly the type of misinformation we hope to tackle with the Aerial Platform Council of the SIA. The manufacturers and OSHA are doing a terrible job of communicating fall protection requirements, and there are many workers doing the wrong thing and possibly getting injured or killed because of it. At the very least, when a worker does the wrong thing, many others see them and copy the behavior thinking, “I saw Joe do it, so it must be okay.”

 

This is only the tip of the iceberg on fall protection alone. There are many other questions and bad behavior out there that somehow becomes fact only because so many workers are doing it and doing it wrong.

 

Your publication and others can help get the word out, but it has to be the same “word” and not a mixed message of opinions.

In your case, the first question to ask is: Which company's boom lift are you using? Then call that manufacturer and ask them if what they want to do is okay. Ultimately, it comes down to “What the manufacturer says” and nothing else really matters.

 

Using personal fall protection in a scissor lift is probably the most popular discussion point. While OSHA doesn't say you have to, many manufacturers “recommend” it. So have you ever been on a scissor lift with a 6-foot lanyard • the maximum length OSHA allows • and tried to stay hooked up to an anchorage point? It is impossible unless you use a double lanyard and even then it is a challenge and requires special training.

 

That is just one example of theory versus real life.

 

Jeff Stachowiak

Sunbelt Rental

Jacksonville, Fla.

 

In addition to the OSHA regulations, the ANSI standards also need to be referenced. In this case, it's not clear whether the operator is leaving the platform to get to the elevated jobsite, but the ANSI standards specifically address the conduct of the operator.

 

A92.6 8.10 (28): Vacating (or entering) an elevated aerial platform. If permitted by the manufacturer, personnel shall only vacate or enter a raised aerial platform by following the guidelines and instructions provided by the manufacturer.

 

Operators are not to leave or get out of the platform unless the manufacturer has provided that use.

 

Barris Evulich

Chairman of ANSI A92.5

 

I enjoyed your article. I was thinking though that somewhere in the safety manuals it states that the aerial lift platform is not to be used for transporting people, only elevating people. By that description, you are not supposed to get out of the basket • period.

 

Then there is the side load factor, especially for scissor lifts. When the machines are lift tested, they must withstand a certain percent of the lifting capacity for the side load. How much side force would it take to tip over the machine? If the person is out of the confines of the basket and he was to fall, his weight alone could topple the machine. The side load capacity is really very minimal • I think it is somewhere around 100 to 150 pounds on a 1930 Genie, for instance.

 

My vote would be: No, you cannot use the aerial lift as an anchor point.

 

Todd Moir

EquipWholesale.com

Santee, Calif.

 

If the platform appears to be empty from the ground, personnel on the ground may attempt to operate the lift from the ground controls. If this were to happen, I would not want to be attached to the lift.

 

Anonymous