Open Dialogue for Fall Protection
January 25, 2006 — Discussion on properly equipping aerial lift operators with fall protection is nothing new, but sometimes a magazine article, e-mail, or conversation reminds you that it's never a bad time to continue the dialogue.
Katie Parrish
Last week, a reader contacted me while looking for information on using an articulating boom lift as a tie-off point for fall protection when the worker is located outside the platform. He wrote: “I have found that some supervision think that it is okay to tie off to lifts when the employees are outside the basket. The reason they give is that they are still tied off to the same anchorages as before when inside the basket. I don't think that is what the manufacturer or OSHA had in mind, but I can't find any supporting data.”
The reader and I emailed back and forth, cutting and pasting lines from OSHA 1926.502 and sending each other links to different websites with tidbits of information about anchorage points. No cut-and-dry answer was found, so I consulted two safety professionals • Rob Vetter, technical director and managing partner of Ives Training Group,
Through our research and talks with these safety professionals, the consensus is there is no specific OSHA regulation that prohibits tying off to a boom lift from outside the platform because it's not even considered by OSHA as an anchor point when working outside the platform. Backing up our conclusion was “Fall Protection: Sorting Out the Regulations and the Regulators,” a presentation written by Dave Merrifield of Merrified Safety Consulting.
According to Merrifield: “[In] ANSI and OSHA, the attachment point shall be capable of withstanding the force of 3,600 pounds for each allowed person on the attachment without reaching ultimate strength. The strength requirement according to ANSI applies only to the attachment point and not to the boom or platform. Thus, the aerial lift structure is not considered an anchorage like a building column or beam, and it is not contemplated in ANSI that it will be used as part of a fall arrest system for people standing on guardrails (not allowed) or working on an adjacent structure.”
Vetter also made a solid point about using the boom lift as an anchor point. He said that although he did not know of a specific regulation that prohibits tying off to the boom lift from outside the platform, he knew that OSHA has specific regulations specifying the maximum allowable load/force that a fall protection anchor point is designed to handle.
“In my opinion, if a worker wanted to leave the platform and remain anchored to the boom lift, they would have to use quite a long lanyard,” Vetter said. “In the event of a fall, the forces exerted on the anchor point may exceed the allowable limit(s) listed at CFR29 1926.502(d) due to the fact that a long lanyard would allow too long of a vertical drop to occur before engaging, which would overload the anchor point.”
Boehler also said he was not able to find anything with regards to tying off to an aerial lift while standing on another surface. An OSHA interpretation letter he mentioned in his email regarded scaffolding as an anchorage point, which OSHA said should not be used unless it has been properly evaluated by a competent person. “I cannot speak for the entire industry, but I would certainly not recommend this practice,” he said. “Skyjack recommends travel restraint, as opposed to fall arrest, and obviously having enough slack in the lanyard to allow the occupant to an adjacent surface is not restraint, and would then rely on arrest.”
Practically on the same day as my discussions with the reader, I noticed another industry publication was discussing the same topic. While there is no specific OSHA regulation that says using an aerial lift in this way is wrong or right, the aerial lift industry tends to view this as bad practice.
Equipping operators with fall protection only brushes the surface in providing for a safe operating environment. Even when operators are properly equipped with fall protection, an accident can happen if they are not trained on the correct way to use it. If you'd like to comment or have some insight into tying off to an aerial lift while outside the platform, please e-mail me at kparrish@liftandaccess.com. We'd love to continue the dialogue • it will only create a safer workplace.
