In January 2009, OSHA released a letter of interpretation regarding the use of a shock absorbing lanyard in an aerial lift. The issue of contention was the fact that in most cases, a 6 foot shock absorbing lanyard would require the user to be at least 18 ½ feet off the ground in order to be protected from contacting the lower level, in the event of a fall. OSHA’s interpretation clearly outlined the guidelines stating “a body belt [or body harness] shall be worn and a lanyard attached to the boom or basket when working from an aerial lift.” This is followed up by the regulations within subpart M prohibiting free fall of greater than 6 feet or contacting a lower level. This interpretation has or will change the way most employers outfit lift users with fall arrest equipment.
A new memorandum released August 22nd, 2011 has effectively rescinded the January 2009 interpretation letter, as OSHA felt there was too much confusion regarding the issue. The memorandum has made an attempt at clarifying the regulation and how compliance officers will be applying it in the field.
The basics of the memorandum are to outline the restriction of the use of 6 foot shock absorbing lanyards for employees in an aerial lift. OSHA is not directly stating that you cannot use such a device, only that its use for operations under a height of 15-16 feet would effectively expose an employee to contacting the lower level should they fall from a lift basket. If you are working in a lift at a height of 8 feet a standard 6 foot shock absorbing lanyard would not prevent impacting the ground, and it is likely to warrant questions or a citation from the compliance officer. It is the employer’s responsibility to equip employees with devices that limit the free fall distance to less than 6 feet and to prevent such contact, regardless of the working height.
This new guideline now opens another line of questioning regarding the height that the rule is actually applicable. In other words, what if you were working from a height of less than 3 feet from the ground? Most people might say “get a ladder”, but the reality is if a lift is in use, it will likely be used for all elevations. But the range in between 0-5 feet now poses another question: Even with a shorter lanyard or retractable, how can the employee be properly protected from contact with the lower level? This issue is not specifically addressed in the new memorandum. Even in the best of circumstances, impact with lower work levels is possible regardless of the length of the lanyard, but employers must rely on the views of the compliance officer and work within the guidelines of reasonable expectations.
The end result of this new memorandum is the enforcement of utilizing shorter or retractable lanyards for aerial lift use. If the harness is equipped with positioning rings, then it is acceptable to use those points to anchor to the lift with a positioning device until an acceptable working height is reached where a 6 foot lanyard would be safe. The days of using standard 6 foot lengths for most employees are over. Employers need to understand not only the reasons why OSHA is taking a closer look, but also the likelihood that such use could garner a citation.
If your employees use 6 foot lanyards for all aerial lift use, it’s time to reevaluate your needs and begin to supply users the right equipment for the job.
For more information regarding the letters of interpretation, the links are listed below.
January 2009 letter (recinded)
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27382
August 2011 Memorandum
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27731
Related Topics: Aerial Lifts, Safety Articles, Monthly Safety Topics