While some fall protection issues are black and white, there are others that fall into a gray area. One of these gray areas involves using aerial lifts to carry employees to overhead stations. Prior to May of 2001, this was an issue that was very confusing in the fall protection community because OSHA regulations require any worker in an aerial lift to be anchored to the lift with a restraint or fall arrest system. Then in 2001, OSHA released a letter of interpretation stating this regulation on aerial lifts does not prohibit a worker from exiting or entering an aerial lift basket that rests on or adjacent to an elevated surface.
However, when employees move from the basket to the elevated surface, the requirements in OSHA 1926, subpart M,may apply. Workers entering or exiting a lift must be safeguarded from any unprotected sides or edges. This can be accomplished with the use of guardrails, a fall restraint or a fall arrest system. Subpart M also elaborates within 1926.502(d)(16) that, “personal fall arrest systems, when stopping a fall, shall be rigged such that an employee can neither free fall more than six feet nor contact any lower level.”
In January of 2009, OSHA attempted to answer a question regarding the use of lanyards that require 18.5 feet of clearance. As a general rule, a lanyard that requires 18.5 feet of clearance is going to be a six-foot energy-absorbing lanyard. To reduce the clearance needed, the worker can use a restraint system, a shorter lanyard or a self-retracting lifeline that has been approved for use in such applications. (Capital Safety manufactures these SRLs, and more information can be found in Capital Safety’s Technical Bulletin SLR008.) Of course, companies should always check the equipment manual for proper clearance instructions for all personal protective equipment.
The gray area is this: Competent persons, as deemed by the employer, know that using a six-foot energy-absorbing lanyard will not meet OSHA requirements because the lanyard will not protect a worker from striking objects below in the event of a fall. (The object in this case would be the ground when moving the lift from one location to another when the lift is in the lower position.) Keep in mind that employees also leave the lift to perform specific tasks when they cannot reach the work site due to obstructions, though working from the lift is always much safer. This demonstrates that the worker does not have 18.5 feet of clearance below and that a six-foot energy-absorbing lanyard is not the right tool for the task.
From a training specialist’s perspective, this is an issue that confronts companies time and time again. The best solution for employees working from aerial lifts, when feasible, is to use a fall restraint system. However, if the worker requires more mobility for the task either within the aerial lift or outside the lift, the next best solution is to use an approved SRL.
The fall protection industry offers several different SRL options to achieve this goal. Capital Safety manufactures a 10-foot Rebel SRL with a swivel snaphook (#AD111BR)- the Rebel attaches to the anchor in the aerial lift. Also, the harness being worn by the worker should have a tie-back talon (#3101300) attached to the webbing of the harness. This allows the employee to attach the tie-back talon to the appropriate anchor at the work location still maintaining 100 percent fall protection.
Finally, workers should remember to never attach a snaphook to a dorsal D-ring that already has another connector on it. This violates OSHA 1926.502(d)(6).
There are many other ways in which competent persons can keep workers safe at heights. For more information, Capital Safety offers a basic competent person course which covers this topic and many more.
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