We have a serious debate here regarding what type of fall protection is supposed to be worn in a Small Platform style Genie Lift. I’ve read a lot on your site and others, but still can’t seem to find the conclusion. The lift is used for entertainment lighting purposes in a controlled level environment. Hook off to the U-bolt anchor point in the basket, the grid (where the lift operator now has to decide if what he’s tying off to is rated), or nothing?
The higher the anchorage point toward and beyond the shoulders the better.
Less fall distance means less swing and probably less force see “Introduction to Fall Protection, 3rd Edition” (available for purchase on this site) for electrical and general maintenance anchor suggestions in sketch form. Sketches are probably the best way to demonstrate what should be done.
Let us know what you think aand we will direct you toward the stability tests done by NIOSH.
Recently I did refresher training for a client that involved man lift stock picker PITs manufactured by Crown. Their training DVD on one machine shows
the use of a lanyard and body belt to protect the operator from a fall when he/she has to leave the operator’s area to manually load/unload a pallet, a typical practice.
My understanding of the latest fall protection requirements does not permit a body belt for this type of operation; rather a full harness with either a shock absorbing lanyard or a retractable lanyard would be required. When
questioning Crown about they sent me a letter of interpretation received from OSHA, dated 2002, that stated that a body belt was acceptable. I have attached a copy. My understanding of the current regulations is that body
belts may be used for restraint or positioning, but may not be used for fall arrest, and fall arrest is what would be required if an employee fell from an elevated lift.
The authority for using belts in general industry comes from the standard governing stockpickers ANSI B56.1 and OSHA is only as strong as the associated industry wishes to be safe. The belt or harness option has remained for decades in the B56.1. In its letter 2002 OSHA (Richard Fairfax)
has offered that belts have drawbacks and advises that the use of harnesses is preferred. There have been no fall protection regs in general industry since 1971 (except for 1910.66 Exterior Building Maintenance in 1989 and a
few other industries or types of work such as electrical maintenance).
That is likely to change with the issue on May 24 2010 of the re-proposed general industry fall protection Subpart D 1910.21-30 plus subpart I with appendices. Comment period ends on August 23rd 2010 without extension which
will probably be granted as we approach that date. If that new standard goes into effect all letters of interpretation for that standard will cease to exist if OSHA repeats itself with previous updated standards.
So the question that Safety Professionals should ask is “What are the hazards facing a stockpicker operator and how does wearing a belt increase and a harness reduce those hazards if at all”.
The innovation that Crown Controls introduced approximately 30 years ago is the anchor mast over the loading platform. Add to this a small retractable lanyard and the optimum protection (without swing fall consideration from the racks) was achieved for operators. However a furniture store that was the main customer at the time had some operators who felt that large mattresses could not fit properly on the platform and slowly the boom was left out of purchases instead of the bar being raised and the SRL or lanyard
was attached to the overhead protection guard above the operator’s station. This meant that the lanyard had to be increased in length to 8 ft to enable operator walking flexibility. It also introduced a higher hazard from swing
falls. Add to that the operators’ propensity to travel in the rack opened up all sorts of fall hazards. So currently Crown appears to offer a body belt
standard equipment with a non shock-absorbing lanyard. Options are available with shock-absorbing lanyards and harnesses. Crown offers the argument on its web site that body belts (which it erroneously states are “safety
belts”) will be likely worne all the time by operators which it calls “always wearing fall protection” even when not hooked up, and are easier one-size pretty much fits-all and are non-personalized compared with
harnesses which are more personalized and may not be worn all the time during a shift. In other words being attached by belt is more attractive a proposition to customer managements than only sometimes being attached if
wearing a harness. So the story goes.
I think there are some significant fall hazards faced by belt-wearing and straight web lanyard-using-operators which customers may not be aware of
until an injury or fatality occurs. The usage is very hard on the fall equipment and retractables receive hundreds of thousands of cycles plus impacts during picking and stocking phases in busy warehouses. Discipline is
difficult in aisles where pickers cannot be easily viewed. There are
typically at least two shifts which makes personalizing equipment difficult.
There will remain a higher demand for adequate training. If we can train “only one foot in the rack” chances improve for successful fall protection;
monitoring is necessary until the culture changes.
The problem of swing falls from
the rack remains and tight rules must be enforced because workers frequently do not understand that swing falls contain the same energy as a vertical fall only realized if an impact occurs.
Using Dave MacCollum’s book (Construction) Safety Engineering Principles will help in listing a site specific series of fall hazards facing operators
which can then be tackled. Let’s find some success stories!
We are trying to get our mill to implement a best practice of using Fall Restraint in a man lift by using a retract-a-lock that doesn’t limit your mobility in the basket but, at the same time, won’t allow you to fall and potentially tip over the lift. Do you know of any incedents where these kind of falls have occured.
No tip over has occurred to my knowledge. A tip over is unlikely due to low inertia of decelerated fall arrest. Check the paper in Human Factors Journal in 2011-2012 by Chris Pan of NIOSH who tested one scissor lift without tip over in several drop tests.