According to a recent study by the International Powered Access Federation (IPAF), the use of aerial work platforms (AWP) has been increasing. This expanding user base is one of the reasons that the American National Standards Institute (ANSI) safety standards for AWPs have been under revision (Rubenstone, 2016). The new ANSI A92 standards are expected to include changes to terminology, design, use, and training, and are expected to be issued in early 2017 (Groat, 2016). Terminology changes will include the name of the equipment itself, as well as the classification of equipment. Regarding the name, AWPs will now be known as Mobile Elevating Work Platforms (MEWPs). Equipment will be classified by “group” and “type”. Group “a” will be utilized to identify vertical platforms, which are commonly referred to as scissor lifts, whereas group “b” will be utilized to identify all other MEWPs, commonly referred to as boom lifts. The “type” will indicate the ability of the equipment to travel when stowed or elevated, and the location of controls that enable such travel (Groat, 2016).
One significant design change is that MEWPs will be required to be equipped with platform load sensing. Those familiar with this type of equipment know that each platform has a rated capacity that is not to be exceeded, and is often dependent on elevation and radius. This new design requirement will now prevent the operator from moving the platform if its capacity has been exceeded (Groat, 2016). One significant addition to the safe use standard is the requirement for a risk assessment to be conducted prior to operation. The process of risk assessment will enable the operator and other affected workers to identify potential hazards, and develop methods to eliminate or control such hazards. Among other considerations, the risk assessment must include the effect of wind and other weather conditions, as well as the development of a rescue plan (Groat, 2016). In addition, the safe use standard is expected to include provisions for equipment inspection documentation, worker selection, hands-on training, work on public roads, work near energized conductors, and the practice of exiting the MEWP while elevated (Groat, 2016).
Exiting the platform while elevated has generally been prohibited, but considered to be acceptable with instructions and guidelines provided by the manufacturer (Groat, 2016). In my experience, it is common to see workers use both scissor lifts and boom lifts as a means of access to elevated surfaces. To be clear, the Occupational Safety & Health Administration (OSHA) does not prohibit this practice. In fact, OSHA provides clarification in a letter of interpretation issued on May 3, 2001, in which it is explained that OSHA standards do not prohibit employees from exiting or entering an aerial lift basket that rests on or is adjacent to an elevated surface. The letter clarifies that fall protection must be utilized, and that the particular OSHA fall protection standard that is applicable changes from 29 CFR 1926.453(b)(2)(v) when in the aerial lift basket, to 29 CFR 1926 Subpart M during transition to, and when on elevated surfaces 6 feet or more above lower levels (Swanson, 2001).
The new ANSI safe use standard for MEWPs is expected to include provisions for a qualified person to develop site-specific guidelines, as part of the required risk assessment described above, for exiting / entering the platform while elevated. This is important because guidelines provided by the manufacturer are typically general in nature. In addition to following the manufacturer’s general guidelines, the qualified person will need to evaluate conditions and practices on a site-specific basis, and develop procedures accordingly (Groat, 2016).
You may be asking yourself, aren’t ANSI standards voluntary? The answer is yes and no. ANSI A92.2-1969 was incorporated by reference as part of OSHA Subpart L, and is legally enforceable. Although current versions of ANSI A92 have not been incorporated by reference, consensus standards such as these can serve as a basis for OSHA citation when conditions and/or practices warrant. In such circumstances, OSHA can invoke the General Duty Clause of the Occupational Safety & Health Act of 1970, which requires employers to provide employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees (Swanson, 2005).
Therefore, it is important to stay current with regard to both regulatory and consensus standards, as well as the manufacturer specifications of the particular equipment being utilized. As with any effort to provide a safe working environment, pre-planning is imperative. If you have any questions or concerns, please contact the Safety Check, Inc. office.