Does anyone have ideas about the practice of using an aerial lift to gain access to a higher work level? Our employees typically do this, staying tied off 100% of the time to either the lift basket, the higher level being accessed, or both (as they leave the platform to move over to the higher level or back again). Thanks

leestocks:

Does anyone specifically prohibit exiting a manlift to move to an elevated work surface,as long as the worker remains tied off 100% of the time; ie, has two lanyards on his body harness so that he is never without fall protection? I don't see an OSHA prohibition, but wanted to see if any companies saw a reason to prohibit this practice. A shipyard customer of our has said they don't generally condone it, but will allow certain contractors to do so if it prevents a worker from having to make repeated trips up and down steps.

In my opinion there is no OSHA prohibition.  You can climb on, off or around just about anything if you have appropriate fall protection.  As long as they don't climb over the guardrail system, I don't see a hazard.

The scaffold rules explicitly allow it in 1926.451(e)(1).  Not that an aerial lift falls under the scaffold rules (although they are in the same subpart - L), but it's a similar principle.

Straight from OSHA (assuming we're discussing construction):

1926.453(b)(2)(iii)

Belting off to an adjacent pole, structure, or equipment while working from an aerial lift shall not be permitted.

1926.453(b)(2)(iv)

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.

1926.453(b)(2)(v)

A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift.
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Now this is open to interpretation because a scissor lift is considered an aerial lift and it is also considered a mobile scaffold (this was told to me by Virginia Ames, OSHA compliance assistance specialist).  This throws out a LOT of grey area in my opinion because I'm having no luck finding any standard about employees remaining inside the boundaries of the scaffold.

-Justin

I know it's a bit of an old topic, but I figured I'd throw in some clarification.

An aerial lift is different from a scissor lift by OSHA standards.  A scissor lift is considered a mobile scaffold.  Virginia Ames (with OSHA) discussed this issue with us.  In an aerial lift...

29 CFR §1926.453(b)(2)(iii)
Belting off to an adjacent pole, structure, or equipment  while working from an aerial lift shall not be permitted.

29 CFR §1926.453(b)(2)(iv)
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.

29 CFR §1926.453(b)(2)(v)
A body [harness] shall be worn and a lanyard attached to the boom or basket when workking from an aerial lift.

Hope this brings some clarification.

-Justin

SPDSKTR:

I know it's a bit of an old topic, but I figured I'd throw in some clarification.

An aerial lift is different from a scissor lift by OSHA standards.  A scissor lift is considered a mobile scaffold.  Virginia Ames (with OSHA) discussed this issue with us.  In an aerial lift...

29 CFR §1926.453(b)(2)(iii)
Belting off to an adjacent pole, structure, or equipment  while working from an aerial lift shall not be permitted.

29 CFR §1926.453(b)(2)(iv)
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.

29 CFR §1926.453(b)(2)(v)
A body [harness] shall be worn and a lanyard attached to the boom or basket when workking from an aerial lift.

Hope this brings some clarification.

-Justin

Never looked at scissor lifts that way, but it makes sense and certainly seems to fit within the definition of a mobile scaffold.  So, the access question is explicitly allowed in the scaffold rules (1926.451-e-1).

From what I understand after reading the terminology, as long as you have some type of fall protection at your point of access, you'll be in compliance.  Also, from what I've read, I interpret it as, "It's legal to exit the lift by not climbing over, sitting on, or standing on the rails as long as appropriate devices and proper fall protection is being used" (since it goes back to the 6' rule after exiting the lift).

Anyone agree?  Disagree?

Scissor lifts are a thing that seem to have never-ending debates.  Trying to use OSHA's "grey language" in a situation like this doesn't help either.

-Justin

P.S.:  It's not required by Federal OSHA to tie off in a scissor lift.

SPDSKTR:

From what I understand after reading the terminology, as long as you have some type of fall protection at your point of access, you'll be in compliance.  Also, from what I've read, I interpret it as, "It's legal to exit the lift by not climbing over, sitting on, or standing on the rails as long as appropriate devices and proper fall protection is being used" (since it goes back to the 6' rule after exiting the lift).

Anyone agree?  Disagree?

Scissor lifts are a thing that seem to have never-ending debates.  Trying to use OSHA's "grey language" in a situation like this doesn't help either.

-Justin

P.S.:  It's not required by Federal OSHA to tie off in a scissor lift.

I agree with you, I think.  Workers shouldn't climb over the rails, however, even if they are tied off.  That can still result in injury and since the lifts have built-in means of access/egress, I think it's hard to justify.

And, yes, it is not required to be actually tied off while in the scissor lift itself.  Once you step out, however, if there is exposure to a fall hazard greater than 6 feet, then fall protection must be used.

TheFIRM:

I agree with you, I think.  Workers shouldn't climb over the rails, however, even if they are tied off.  That can still result in injury and since the lifts have built-in means of access/egress, I think it's hard to justify.

29 CFR §1926.451(e)(1)
When scaffold platforms are more than 2 feet (0.6 m) above or below a point of access, portable ladders, hook-on ladders, attachable ladders, stair towers (scaffold stairways/towers), stairway-type ladders (such as ladder stands), ramps, walkways, integral prefabricated scaffold access, or direct access from another scaffold, structure, personnel hoist, or similar surface shall be used.  Crossbraces shall not be used as a means of access.

Just a little interpretation there...

-Justin

EDIT:  Letter of Interpretation.  I interpret the interpretation as, "An employee's foot should never touch the guardrail."  (Link will open in new window.)

I think we're pretty much in agreement. 

Whew!  I feel like a scissor lift safety expert after all the debates I've been through about them. 

-Justin