What OSHA’s Modified Guidance on Work Platform Fall Protection Means for Users

James Maddux, director of OSHA’s Directorate of Construction, has rescinded a January 2009 letter of interpretation regarding the use of a particular shock-absorbing lanyard in aerial work platforms (AWPs). According to Maddux, the directorate was inundated with questions from end users and employers, as well as OSHA personnel, asking if OSHA’s 2009 letter banned the use of the landyard.

“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, that it was likely that the lanyard’s use would not comply with OSHA standards at lower heights,” said the memo from Maddux, who added, “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.

The 2009 letter of interpretation had created uncertainty in the industry by suggesting that a manufacturer’s requirement for a minimum anchorage point elevation of 18.5 feet would prevent the use of a fall protection system (6-foot lanyard with shock absorber, full body harness) in an aerial lift.

“In rescinding this letter, OSHA is not concluding that the application described above is acceptable, rather it is clarifying that fall protection systems should not be based solely on information provided by the manufacturer, but should also take into account OSHA regulations and results of the job-specific risk assessment,” said Tony Groat of the International Powered Access Federation (IPAF) USA. According to Groat, IPAF believes that the primary choice for fall protection should be a restraint system, to stop the fall in the first case.

IPAF, in its 2007 technical guidance H1, provides recommendations for personal fall protection in AWPs. This guidance states, “When working from a boom-type AWP, it is strongly recommended that a full body harness with an adjustable lanyard be used to provide work restraint. The lanyard should be adjusted to be as short as possible (and may have a shock absorbing section if permitted by the AWP manufacturer).”IPAF has also worked with other industry associations to produce the Statement of Best Practices of Personal Fall Protection Systems for Aerial Work Platform Equipment. This educational document clarifies when and how to use PFP systems on AWP equipment and is based on ANSI standards.

Both this document and technical guidance H1 are available at the Publications section of http://www.ipaf.org and http://www.awpt.org.

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