Complex Applicability

By David H. Glabe, P.E. / August 31, 2011

An appraisal of the codes and standards that apply to aerial lifts, including boom lifts and scissors lifts.

Sometimes it’s simple, sometimes it isn’t.  When it comes to aerial platforms, such as boom lifts, scissors lifts, mast climbers and the like, the applicable OSHA standards get twisted, misapplied, and misused.  What causes this, you ask?  Well, maybe you don’t ask, but here it is anyway!

First a little history:  When OSHA decided to revise the Construction Industry scaffold standards, it was determined that aerial platforms (OSHA calls them aerial lifts), would be included.  Since aerial platforms are a very specific type of scaffold, OSHA acknowledges this fact by clearly stating in the Scope and Application [29 CFR 1926.450(2)] that “The criteria for aerial lifts are set out exclusively in §1926.453 of this subpart.” To further emphasize this exclusivity OSHA restates the obvious in the General Requirements, §1926.451, stating that “This section does not apply to aerial lifts, the criteria for which are set out exclusively in §1926.453.” What all this means is that none of the scaffold general requirements, including fall protection, access, platforms, and falling object protection to name a few, apply to aerial platforms.

In theory, for aerial platforms, all of this information is contained in §1926.453.  And this, in my opinion, is where the confusion begins.  §1926.453 references an American National Standards Institute standard, ANSI A92.2-1969.  Furthermore, OSHA describes the equipment it considers to be an aerial lift:

(i)                 Extensible boom platforms;

(ii)               Aerial ladders;

(iii)             Articulating boom platforms;

(iv)             Vertical towers; and

(v)               Any combination of any such devices.

The 1969 in the standard is the year 1969.  This was the current standard when the scaffold standards review began.  Consequently this is the standard that was used to establish the definition for an aerial lift.  And therein lays the problem since there has been a substantial growth of aerial platform types since 1969.  Fortunately OSHA recognized that new types of aerial platform equipment and ANSI standards have been introduced into the market since 1969. A note was added at the end of §1926.453 in the OSHA standards that recognizes the ineffective applicability of the 1969 ANSI standard by referring the reader to Non-mandatory Appendix C which “lists examples of national consensus standards that are considered to provide employee protection equivalent to that provided through the application of ANSI A92.2-1969, where appropriate.”  Non-mandatory Appendix C lists ANSI A92 Consensus Standards which apply to the aerial platforms that are familiar and common today.  Included in this list are familiar aerial platforms such as “Boom Supported Elevating Work Platforms” and “Mast Climbing Platforms.”

In practical terms, the referenced ANSI A92 standards are the best resources to use to ensure safe use of aerial platforms.  In fact, a review of OSHA §1926.453 will quickly illustrate the deficiencies of OSHA §1926.453.  This is said not to criticize the OSHA standards but rather is a statement of fact concerning the limitations of the OSHA standards regarding aerial platforms and the legal restraints that often stifle standards writers’ efforts.  The ramification of all this is confusion!  Interestingly, the scaffold General Requirements, §1926.451, are frequently cited as applicable to aerial platforms.  This is incorrect although common practice would indicate otherwise.  Additionally, OSHA §1926.452, Additional Requirements Applicable to Specific Types of Scaffolds, does not apply since aerial platforms are “exclusively set out in §1926.453.”   Clear to me; clear to you?

In legal or perhaps technical terms the outcome of standards application is a bit different.  This shows up in an OSHA Letter of Interpretation that opines that “Self Propelled Elevating Work Platforms” (ANSI A92.6), commonly known as scissors lifts, are not aerial platforms/lifts but rather “Mobile Scaffolds.”  Due to the constraints and wording of the language in §1926.453 and the ANSI A92.2-1969 standard, it is argued that scissors lifts are not included in the ANSI A92.2-1969 standard.  Thus, scissors lifts are not aerial platforms/lifts.  If they are not aerial platforms/lifts, they must be something else.  I guess since a scissors lift has an elevated platform and it has wheels, it can be concluded that scissors lifts are rolling scaffold towers.  Using this logic, helicopters, airplanes, forklifts, Airline Ground Support Vehicle-Mounted Vertical Lift Devices (ANSI A92-7), and boat trailers can be considered rolling scaffold towers!

What’s the bottom line?  The scaffold General Requirements do not apply to aerial platforms.  The scaffold Additional Requirements Applicable to Specific Types of Scaffolds  do not apply to aerial platforms.  In spite of OSHA’s opinion that scissors lifts are Mobile Scaffolds, scissors lifts are aerial platforms.  After all, I would think the industry should know what their equipment is; I hope you agree.

Tags: Aerial Lifts Mast Climber OSHA Standards & Regulations Resources

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David H. Glabe, P.E.

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