Reflection on Fall Protection
Offering safety consulting and litigation services, Merrifield is the principal of Merrifield Safety Consulting, located in
David Merrifield
March 22, 2006 • In this industry, rules and regulations have different status, depending on whether they are law, standard, or guideline. Everyone knows OSHA is law • being out of compliance with OSHA is breaking the law, and behavior is policed. But ANSI is what is known as a voluntary standard. Although it's not against the law to disregard ANSI, it's also not a good idea because ANSI sets the industry standard of practice. If you have ever been sued, you know that ANSI is the standard of care. If you fail to meet it, you look very bad in the eyes of the jury. Then there are the manufacturer's instructions, which are important because the manufacturer knows more than anyone about the product and expects both OSHA and ANSI to be followed. Finally, there are the rules and regulations formulated by the owners and users of the aerial lifts. These must be consistent with the upper layers of the hierarchy -- authority is broken down as follows:
- Federal OSHA
- State OSHA
- ANSI
- Manufacturer
- Owner/employer safety rules
ANSI is actually not a subordinate of OSHA because the two have separate (although overlapping) scopes. ANSI has a lot to say about safe design, whereas OSHA is mostly concerned with safe practices in the workplace.
Generally, rules and regulations can get more stringent as you move down this hierarchy. For example, ANSI should not make a standard contrary to OSHA, the manufacturer shouldn't do things that conflict with ANSI or OSHA, and the owner/employer shouldn't disregard ANSI, OSHA, or the manufacturer's instructions.
ASC (the committee that writes ANSI standards) cooperated with OSHA to come up with fall protection language that's mutually agreeable. In a nutshell, it states:
- The guardrail is adequate fall protection for machinery that elevates within its own footprint. Additional fall protection is needed for a boom-supported work platform because of the potential for being pitched out if the base rotates.
- There is one small area of disagreement between ANSI and OSHA. ANSI says don't remove the guardrails except in one special case, and OSHA says if you do remove the guardrails, you must substitute other protection like personal fall protection.
- Notice: Always check the state or provincial regulations in your area. They may be different from OSHA or CSA (Canadian Standards Association). Finally, check the manufacturer's instructions, which may be more stringent than even OSHA or ANSI.
Following are some fall protection guidelines regarding different types of lift equipment from the industry's governing and advisory bodies.
Manually propelled
According to ANSI, OSHA, and CSA, guardrails are adequate fall protection. Remember, though, that if sections of the guardrail system are removed or lowered, then additional protection is required. Guardrails can only be removed in the special case of machines designed to be order pickers. Other fall protection, such as fall restraint or fall arrest, must be substituted for guardrail protection.
Self propelled (scissor)
According to ANSI, OSHA, and CSA, guardrails are adequate fall protection. Unlike OSHA, ANSI does not permit removing parts of the guardrail, but it does require additional fall protections like fall restraining or fall arrest.
Anchor points were originally added to scissors due to the request and requirements from local authorities, such as owners and users. It's up to the local authority to decide if the lifts are safer with or without fall protection.
A special case (where personal fall arrest is required on a scissor lift) can be created if a worker wishes to transfer from the aerial device to an adjacent structure. ANSI leaves it up to the manufacturer to specify if this is allowed and if so, how it should be accomplished.
Boom supported
Because there is a risk of being pitched out of the platform if the base rotates, booms have required fall protection since the beginning of aerial lift regulation. OSHA requires that a person be either restrained from reaching the point of fall or provided with fall arrest. If the person can fall over the guardrail any distance, then personal fall arrest is required.
ANSI echoes this regulation. Technically, OSHA allows a belt to be worn in a restraint situation (although most safety professional I know think that belts shouldn't be used at all) but requires a full harness and a method of limiting the force on the body to 1,800 pounds in a fall situation. Here is the fall protection language (italics) in the operator's section of the draft version of ANSI A92.5 (booms) currently going through the ANSI approval process:
Fall protection. While the guardrail system of the aerial platform provides primary fall protection, all occupants of the work platform shall wear either fall restraint or fall arrest equipment as directed by their employer.
Vacating (or entering) an elevated aerial platform. If permitted by the manufacturer, personnel shall only vacate or enter a raised aerial platform by following the guidelines and instructions provided by the manufacturer.
If the manufacturer permits it at all, it will likely require personal fall arrest and a double lanyard to be sure that the worker does not fall between the exit and entrance surfaces.
Components and lift attachments are another important area for owners and users to understand before implementing a fall protection program.
Anchorages
According to ANSI and OSHA, the attachment point shall be capable of withstanding the force of 3,600 pounds (1,800 pounds allowed on the human body in a harness times a factor of two) for each allowed person on the attachment without reaching ultimate strength. The strength requirement, according to ANSI, applies only to the attachment point -- not to the boom or platform. Thus the aerial lift structure is not considered an anchorage like a building column or beam, and it is not contemplated in ANSI that it will be used as part of a fall arrest system for people standing on guardrails (not allowed) or working on an adjacent structure. ANSI does not address the tipping force or tipover hazard were someone to fall from a platform wearing a fall arrest system. Here is the anchorage language in the manufacturer's section of the draft version of ANSI A92.5 (booms) currently going through the ANSI process:
4.12.5 Anchorage(s) for Personal Fall Protection
4.12.5.1 The manufacturer (remanufacturer) shall provide anchorage(s) on the boom or platform.
4.12.5.2 The location of the anchorage(s) shall be identified and the number of anchorages shall equal or exceed the number of rated occupants. More than one occupant may attach to a single anchorage if the anchorage is rated for more than one person.
4.12.5.3 The anchorage(s) shall be capable of withstanding the force of 3.600 pounds for each person allowed by the manufacturer on the attachment without reaching ultimate strength. The strength requirement shall apply only to the anchorage(s) and their attachment to the boom or platform.
4.12.5.4 The anchorage(s) shall be located to minimize lanyard slack.
Despite efforts to increase safety and minimize safety hazards, there are still several emerging and unresolved issues when it comes to fall protection, including the following.
Misuse of the aerial lift as an anchoring device
If a person climbs on the guardrails or removes the guardrails, a tipover hazard can be created if a fall occurs. ANSI says “don't do it.”
Should personal fall protection be required on push-arounds and scissors?
There are those who think that personal fall protection should be required on all aerial devices • not just booms. ANSI and OSHA disagree, but there are still local authorities that require personal fall protection on push-arounds and scissors. There seems to be no way to at the moment that one side will convince the other. The best approach is to provide anchorages to those who wish to use them -- but to inform them that they are responsible for determining how to use them. This means considering the pros and cons of the local situation.
Placement of anchorage points and length of lanyard
Although common sense may lead one to think that the shortest possible lanyard hooked low in the platform would be the best to prevent or minimize the effects of ejection, the standards don't have much to say about this issue. ANSI has made a start where it says, “4.12.5.4 The anchorage(s) shall be located to minimize lanyard slack.”
Rescue and self-rescue
ANSI requires lower controls, which allow a fall worker to be lowered. OSHA says:
1926.502(d)(20)
The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.
Taken together, this seems to mean that an employer must either provide a self rescue system on the fall protection gear or have a persona capable of running the emergency controls close enough to “provide for prompt rescue.”
Striking a lower surface or hazard
OSHA, in its training guidelines, talks about “estimation of free fall distance, including determination of deceleration distance, and total fall distance to prevent striking a lower level.” Boom lifts can position people over traffic, electrical equipment, hot liquids, acid baths, and so forth. It would not be good to drop an operator into any of these hazards. Furthermore, if a worker falls over the guardrail system, there is a hazard of swinging back into the platform or the boom. It makes sense then that the preferred choice be fall restraint • keeping the fall from occurring in the first place. If the restraint is not practical, the fall arrest system should provide for minimum slack, as ANSI says.
Hazards caused by lanyards on a large platform
If lanyards are used on large platforms (big scissor lifts), they may have to be long in order to reach the entire platform, or they may require re-hooking to move from place to place. They may present a tripping and entanglement hazard, particularly if more than one person is aboard. Some manufacturers are offering, or at least experimenting with, attachment systems that allow a shorter lanyard. This subject is not directly addressed in ANSI or OSHA.
