If you have questioned the type of fall protection to use in a boom lift, you are already in a better position than many. I cannot count the number of times I have seen workers in boom lifts with no fall protection at all. What these workers may not realize, is that fall protection (i.e. tie-off) is required at all times when in a boom lift. Unlike scaffolds and other walking / working surfaces, there is no 10-foot or 6-foot threshold at which fall protection becomes a requirement (Braun, 2014).
To an untrained worker, the guardrail system on the lift may seem like adequate fall protection. In fact, the Federal OSHA standard, 29 CFR 1926.453(b)(2)(iv), states that:
“employees shall always stand firmly on the floor of the basket, and shall not sit, climb on the edge of the basket, or use planks, ladders, or other devices for a work position”.
If this requirement is complied with, and the equipment is properly maintained, no one should ever just fall out of the basket. Being thrown from the basket, however, is a different story.
According to an article in the Electronic Library of Construction Safety & Health, half of fatal falls from boom lifts involved being thrown from the basket after being struck by vehicles, cranes, crane loads, falling objects, or when a lift suddenly jerked (McCann, 2001). The guardrail system does not provide adequate protection in these types of incidents, which is why OSHA requires personal fall protection despite the fact that the lift comes equipped with a guardrail system. The Federal OSHA standard, 29 CFR 1926.453(b)(2)(v), states that:
“A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift”.
It is important to note that as of January 1, 1998, body belts are no longer acceptable as part of a personal fall arrest system. A full body harness is required.
So, is any lanyard acceptable? A common practice is the use of a 6-foot shock absorbing lanyard despite many safety professionals insisting that only Self-Retracting Lifelines (SRL) and lanyards short enough to achieve fall restraint meet OSHA regulations. In fact, OSHA seemed to prohibit the use of shock-absorbing lanyards in lifts through a letter of interpretation issued on January 14, 2009. However, a memorandum issued on August 22, 2011 rescinded the 2009 interpretation (Braun, 2014).
The current interpretation is in line with what the applicable OSHA standard for personal fall arrest systems requires (Braun, 2014). The Federal OSHA standard, 29 CFR 1926.502(d)(16)(iii), states that:
“Personal fall arrest systems, when stopping a fall, shall be rigged such that an employee can neither free fall more than 6 feet, nor contact any lower level”.
It is not the free fall that is at issue here, rather it is the potential contact with a lower level. The 2009 letter of interpretation addresses a particular shock absorbing lanyard, which has a manufacturer-stipulated minimum anchor point elevation of 18 ½ feet. The letter goes on to explain that the use of the particular lanyard would not be compliant when the aerial lift’s work platform is at heights less than 18 ½ feet (Connell, 2009).
The effect of rescinding the 2009 interpretation and issuing the 2011 memorandum is that rather than prohibit the particular lanyard in question, OSHA will continue to enforce the existing standard as it is written. Essentially, this means that the user must be familiar with the necessary fall clearance of the fall protection system, and not use such systems where that clearance is not available (Braun, 2014).
Many work activities, including movement of the lift around the work site, take place at heights where the required clearance discussed above is not available. For this reason, the best option for compliance and safety, is a lanyard short enough to keep the occupant within the confines of basket. Of course, it is often necessary to be able to move around the work platform to perform work activities. As such, work platform industry associations have published a best practices document which outlines four options for personal fall protection in aerial work platform equipment. The options outlined in the document are as follows:
The intention of using options 2, 3, or 4, where the user can alternate between fall restraint and fall arrest, is that fall restraint would be utilized when the equipment is moving, and when working at elevations where adequate fall clearance is not available (American Rental Association [ARA] et al., 2011).
Determining which fall protection system to use in a boom lift is not so easy with the OSHA requirement discussed above. In addition, the location of anchorage points on boom lifts can vary. When choosing a lanyard to achieve fall restraint, one must take into account the location of the anchor point on the particular lift being used (ARA et al., 2011).
As with any fall protection system, proper planning, equipment selection, and employee training are all imperative for safety and compliance. The professionals at Safety Check, Inc. can help.