Does a person in a boom truck with 4 ft. sides have to wear fall protection?

Your boom truck bucket has 4 ft sides, or 48 inches height wall, significantly above the 42-inch typical height. However, OSHA has not distinguished this feature to exempt users from using Personal Fall Arrest Systems (PFAS). Guide: if user works with elbows beyond the edge and may step up on the internal framework, answer is yes. Also, bucket failure is becoming more common due to aging fleet of rental aerial lifts. More difficult is hydraulic piston sudden failure - here a PFAS may prevent being thrown onto the road for worse injuries. Note: always wear harnesses and shock absorbing lanyards - belt users may not survive the wait for rescue.

For a more detailed answer send email photo and more precise question.

I have written to you before about the question of using a body harness in an aerial lift. I had a long (years) difficult debate with my employer. I finally resorted to filing a complaint with Cal-OSHA.

OSHA was at first rather non-committal, but ultimately agreed that a fall arrest system could NOT be used with our aerial lifts. They subsequently revised their safety manual to read:

"Fall arrest systems cannot be utilized when working in aerial equipment unless that equipment is designed to support at least 5000 pounds or it can maintain a safety factor of at least two. Because most aerial equipment cannot support this load, personal fall restraint is the preferred fall protection system in aerial lift equipment."

The complete safety manual is on-line at: http://www.dot.ca.gov/hq/opo/safety/safetymanual/Chap_12-2000.doc

I personally feel they did not go far enough in prohibiting the use of fall arrest systems in aerial lifts. They leave the impression that its use may be acceptable in some cases. One safety specialist told me they couldn't outright prohibit fall arrest because he thinks there might be a truck in southern California that has a rated load of 2,100 pounds; and it may be okay to wear a harness with fall arrest type lanyard in that one.

I think he should think again. Fall restraint should be not be the preferred fall protection in aerial lift equipment; it should be mandatory.

I have letters from both Cal-OSHA and USDOL confirming that a fall arrest system cannot be used with an aerial lift unless the anchor point can support 5,000 pounds, or can withstand the impact force of a fall with a safety factor of two. USDOL says there is no known recognized test to determine whether an aerial lift can withstand that force.

A past ANSI 92.2 chairman agreed that very few, if any, aerial lifts could meet these requirements. I should think that any employer who mandates, or allows the use of a fall arrest system in aerial lifts under their control would be in very deep trouble if one should overturn as a result of an arrested fall.

I realize that in many cases (boom near vertical) a fall would be unlikely to overturn an aerial lift. And the shock-absorbing feature of fall arrest lanyards would reduce the force applied to the boom in a fall. There are many cases, however, where the arresting force of a worker falling from a bucket could reasonably result in overturning the aerial lift according to a 1994 abstract, more than 30% of fatal aerial lift accidents involved the worker falling with the boom and bucket, either because of a tip over, or catastrophic mechanical or hydraulic failure.

Fall arrest is the name of the game if you cannot eliminate or prevent exposure to the fall hazard.

It seems the employers are misinformed and reactive whether it comes to employee protection. Their duty is to protect regardless of Cal-OSHA and A92 and manufacturer negligence in this area. Restraint is not viable because of degree of freedom required to work; some lift platforms more than others. The force at worst boom angle is equivalent to a static load of around 1500 lbs if the fall manufacturers can deliver 750 lbf or less (1800 lbs at 900 lbf) so 5,000 lbs is a non-starter requirement. Based on my years in the field as a manufacturer the lowest force for a lanyard with shock absorption is around 550 lbf with good quality control.

You need a 5ft+ anchorage post system in a corner (two for scissor lift) and a SRL to avoid hitting the ground because the 7.5 ft does not apply in the Federal rule 1926.453, it is zero ft. The Cal-OSHA requirement here needs clarification possibly because the big problem is being bounced out the moment you get in the lift and not 7.5 ft!

Keep up the good work - propose to them they test with a static load to determine boom tip over force when the outriggers leave the ground and a piece of thin material can be placed underneath the foot. Then get all the fall arrest equipment manufacturersﾒ data and make a decision!

What is the minimum height before having to wear a harness and lanyard in a man lift?

No minimum height (trigger height)!! Any height! Harness means worn and having it connected such that a person cannot hit the ground or other obstruction (1926.500 series)

That is why an SRL positioned 5 ft above the platform floor in one corner (two for scissor lifts in opposite corners) is the correct answer to avoid foot injury at lower levels. Check the 2nd and 3rd Edition of Introduction to Fall Protection for a sketch.

What's the latest take on tying off inside a scissors lift with railings?

No change. Guardrails should provide fall protection to a properly used scissors lift user. The problem comes leaning over railings. In this case additional FP is required. I have proposed a 5ft high post in the opposite diagonals of the lift for up to two workers. Some advocate floor anchorages that are a lot easier but has many drawbacks.

Geometry is helpful to foresee particular scenarios and predict the outcomes. Manufacturers may not wish to consider this and may not support a Z359.1 testing program to ensure functionality.

The user management has the responsibility to cut through this and make the right decision. If you would like to have the program reviewed, please send me your proposal for a particular model.

I sent this question out to the major fall protection manufacturers and have not yet received a suitable answer. Care to take a try?

Please solve the challenge of the correct fall protection required for a Genie lift. Our unit is a TMZ 50/30 which has a 50 foot height range. I have yet to figure out a system that will either meet restraint codes (best) or fall arrest codes.

Challenges associated with fall protection options for this unit include:

1.) Location of the anchor point(s) well BELOW the harness attachment points,

and 2.) use of the platform/basket in the 5' to 18' height range - 6' shock absorbing lanyard would not work?.

1. Genie's documents recommend a restriction system first, and a fall arrest system second. How could a 2' restraint system be set up on this lift with the it's current anchor location? (Worker mobility).

2. If a restriction lanyard is utilized, is a body belt sufficient? If a harness is used, should the restraint lanyard hook up to SIDE D rings (vs. back)?

3. Should the lanyard run over the top basket rail vs. through the railing of the basket? Over the top means restraint system is impossible (more than 2' fall). Through the rail - what if the basket should fall off?.

It appears three lanyard options are available:

1. Shock absorbing fall arrest type - would any model work at less than 18' ?

2. Self retracting fall limiter - would this work and how would it be mounted (retractor on the harness or on the boom anchor).

3. Non-stretch, restricting type that would prevent falling out of the basket. How do I configure this to allow mobility yet prevent less than 2' fall? Belt or harness?

Please take a look at Dr. J. Nigel Ellis' book, "Introduction to Fall Protection" either the 2nd or 3rd Edition on page 116 Fig 5.2 and 5.3.

I have reviewed your book, with particular attention to chapter 5. To be honest, I am perplexed by the ambiguity concerning fall protection in aerial work platforms (see my original questions herein, if necessary). Why the concern? My supervisor died 2 years ago from a 10 ' roof fall and just recently in our town, an experience lift truck operator died while using his boom to attempt a flag pole removal (he was ejected out of the bucket and landed on his truck). Genie's Written Fall Protection Recommendations: The railing provides primary protection. "The primary purpose of a secondary fall arrest system (lanyard and harness) is to prevent the operator from being ejected (catapulted) from the platform while the machine is traveling. Genie Industries recommends the use of a "Restraint Device" (a device that prevents the worker from falling any distance) whenever possible......" I just called their safety engineer and he acts as if he never read their recommendations and tells me that their "standard" set up is a harness with 4 ' shock absorbing lanyard (which allows you to be ejected and even hit the ground at low heights) His answer - well, it's the higher falls that you really want to worry about! Don't forget, their anchor point is 1 ' above the basket floor. Your recommendations: I see your system as allowing maximum mobility and attempting to make the system idiot proof (operators standing on the mid-rail, etc.). But, even with your system, an operator could be catapulted out of the basket a short distance and violently thrown into the side of the basket or onto the boom itself. Once ejected, then a rescue plan has to be initiated. Based on the principles of car seat belts, would not the safest protection be to not incur ejection and a fall? To me, the best system would be a very short restraint lanyard (2 '+/-), attached to the side D ring and anchored to a "rail" so it could slide sideways on. The anchor point would be low enough that it would be impossible for the operator to be ejected over the top basket rail (or if he did make it over the rail, there would be little or NO fall distance). Another concern I have with your recommendation is that the end user of the lift device is stuck with what the manufacturer provides for an anchor point. To modify and add the anchor system you recommend would pose a great liability unless someone was willing to sign off that it meets all safety standards. Wouldn't this be cost prohibitive for the smaller owner/operators? So......on our Genie 50/30 lift, a 26 inch restraint lanyard attached to the harness side D ring and the one foot high anchor point would almost keep the operator from "rolling" over the top basket rail with little or no fall. This would allow about 80% use of the basket space. I don't see how any other system would meet all of the OSHA/ANSI rules (trigger heights, tip/over-anchor concerns, etc..). Please enlighten me! And...... Thank you for a wonderful book, for your expertise, and for your desire to share it with others.

Good analysis! The bit about restraint only is an old industry shibboleth for the most part - it is addressed in OSHA 1926.453b2v. Fed OSHA Wash DC regards the working in an aerial lift in almost all work situations as a fall hazard requiring a harness. In addition the mobility you address is missing for most buckets and workers will unhook completely or extend the lanyard by hooking an additional lanyard raising roll-out or burst out hazards. The lanyard is something that should be replaced with the SRL and fall equipment manufacturers should be designing to vastly different standards such as 6 or 12 inch total stopping distance instead of 42 inch which is old world and not practical for low heights. I recognize that a vertical boom may act as impalement tool unless protected but I have felt for years that this likelihood is remote using a g-locking SRL (acts and locks in 1/4"). If the bucket turns upside down then any person is going to be left in suspension for quite some time - only a harness without waist belt will do. The fast-acting SRL acts for low height fall-outs by over-reaching so the ground is not a factor. Buckets should probably be 46" rail heights in addition. Boom or basket attachment speaks for itself. The figures in my book stand without change. What's your choice? PS Let me know what you decide. I hope you will lead in this field - it needs clear thinkers to break the mold! You are one of them I feel. Thanks for your comments on the book

Is fall protection required when using a boom or scissor lift?

Boom lifts and scissor lifts are different in background scope and use.

Boom lifts (aerial lifts for people elevation) that are truck mounted require the use of attached equipment to restrain from bucket ejection in the case of street or highway collision. If the free fall exceeds 2 ft then a harness must be used (1926.453 and 1926.500 series).

Scissor lifts typically have a general industry application and also construction use with large wheels. No fall protection is required by OSHA because if the work is central to the relatively large platform, no body parts extend over the railings*. The industry standard is ANSI A92.6.

*Although railings are sometimes lowered for access through doors, the railings must be re-erected for further travel if a person is on the work platform.

Railings can have chicken wire or expanded metal installed to reasonably prevent use of the midrail for a stepping point.

Sometimes, when authorized users have left the platform such as on a commercial roof based on employer policy, fall protection is advisable based on the hazard assessment. In that case, the lift or other anchor must be reviewed carefully. Boom or scissor lifts will be subject to tipping with certain applications and the possibility a swing free fall poses an additional hazard.

If the application would produce the same result as standing inside the aerial lift then the use of common anchors might be approved. Note: Anchors should be at 5 ft height at corner(s) for use with retractables per J. Nigel Ellis and low anchors at midrail or foot level (typically per manufacturers) are problematic. Snaphook compatibility must be reviewed during a fall situation by a Competent Person and a Qualified Person. Likewise, electrical hazards must be reviewed; long free falls potential usage must be reviewed carefull by a Competent Person. Plastic buckets have difficult access that can be hazardous. Serious head injuries are not uncommon lifting a bar or ducking under a fixed rail.

To test an aerial lift for use as a stable anchorage, a tipping test may be acceptable if the manufacturer will not help. Static forces in the direction of fall may cause a wheel to lift and that is not adequate so be sure that all available out-rigggers are properly deployed and the platform is horizontal.

I am looking for clarification on fall protection:

We have 2 manlifts in our maintenance department that we use to do work on the busway, lights, ceilings, columns, etc. Our policy is that employees are required to wear a harness and clip in to the steel hook attached to the base of the manlift (original, installed during manufacture).

Someone argued with me that clipping in to the manufacturer's clip-in point is only intended to restrain the employee from going outside of the basket, and that those points are not intended to provide fall protection if the employee should fall. I agree that you are not supposed to tie-off to any other points such as the rail, and I am not advocating that I want the guys to go outside the basket, but I believe that the tie-off point is intended to provide fall protection (within the rated weight capacity) should the operator fall.

What is the purpose of the clip-in points on a manlift? To restrain an operator from going outside the basket? Or do they provide fall protection in the event of a fall? Or both?

It is clear that 1926.453 is ambiguous, 1910.67 is too ancient, and the A92 series inconsistent and that greater clarification of the specific fall hazards for various kinds of aerial lifts is needed and this often depends on the method of use in each application such as overreaching beyond the railing, climbing, possible electrical contact versus bucket tipping and boom collapse from failure to maintain, floor collapse, auto impact catapulting effect etc.

Also the Wishbone Safety Device for transferring from an aerial lift needs to be explored more for a catastrophic situation.

Each proposed solution/interpretation (including passing liability) to this Safety@List for us Safety Professionals has to be part of something bigger, hence the need for the NIOSH proposed study.

See more answers in this FAQ section.

I need to know what standards are used for fall safey when OSHA does not regulate. I have a municipality incident where the bucket truck operater fell to the ground, no safety belt or harness in use. Are they still somehow required to wear fall protection?

The state invovled may have adopted OSHA in its public employees protection program. Check www.osha.gov state plan approval.

Sometimes the state has Administrative Rules, e.g. Ohio, that work with any employer in the state. Some states have SafePlace Acts that apply across the board.

The hiring organization, employer or agency should have safety rules that require compliance following adequate training.

Sometimes if the worker was following verbal instructions the employer may be liable because a court may determine that it was not an accident, but rises to the level of an intention act on the part of the employer.

Often, based on type aerial lift or lack of training, the worker thinks that the bucket or rail acts as a protective barrier and no further protection is necessary. Sometimes a hole into which the wheel sits or an electric power line close by is enough to propel the worker out of the lift.

If the bucket tips or the boom fails then Tort Liability (Second Statement) prevails. Premises Liability works for liability on any property by the owner.

A boom truck is used to put an employee above a 4/12 pitch roof. The bucket is positioned down the slope from an area that needs attention such as a pipe sticking up through the roof.

The worker, who is attached by SRL inside the boom, steps out through a gate onto the roof with the bucket aligned down slope from him and does work on the pipe. Then he returns to the down-slope bucket, gets in and departs.

What is describe is tethering to the basket of a aerial boom lift. It is not a good practice to do this on a regular basis without constant dilegence, adequate training and montioring but it can be done on a specific situational basis.

As long as you position the basket in line with the worker, in very close proximity to the work area and you do not stray beyond this immediate area (minimal SRL payout) it should be feasible for this particular situation. Positioning the basket along the roof line "down stream" of the worker will cause him/her to slide down towards the basket acting like a toe board if you will helping the worker to be able to regain balance.