- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
March 31, 1980
Edwin M. Burk, P.E.
Vice President-General Manager
United States Waco Corp.
225 So. Fairbank Street
Addison, Illinois 60101
Dear Mr. Burk:
This is in response to your recent inquiry concerning OSHA's requirements for scissor lifts and the applicability of ANSI A92.2-1969, and confirms a telephone conversation with Mr. William Simms of my staff.
29 CFR 1910.67(b)(1) states that unless otherwise provided in this section, aerial devices (aerial Lifts) acquired on or after July 1, 1975, shall be designed and constructed in conformance with applicable requirements of the American National Standard for "Vehicle Mounted Elevating and Rotating Work Platforms" ANSI A92.2-1969, including appendix. Aerial devices include the following types of vehicle-mounted aerial devices used to elevate personnel to jobsites above ground: (i) extensible boom platforms, (ii) aerial ladders, (iii) articulating boom platforms, (iv) vertical towers, and a combination of any of the above. The 29 CFR 1910.67 requirements including the reference to ANSI A92.2-1969 will be enforced until the section is modified in the future.
In regard to OSHA's position on the applicability of ANSI A92.2-1969-for Vehicle-Mounted Elevating and Rotating Aerial Devices, I have attached a copy of OSHA Instruction CPL 2-11A for your information.
It does appear that manufacturers of scissor lifts complying with either ANSI A92.3-1973 or ANSI A92.6-1979 and the manufacturer's operating instructions stating the restrictions and requirements for safety as required in each standard, would not be in violation of any OSHA standard. However, employers using the equipment in an unsafe manner may be cited in accordance with section 5(a)(1) of the Act.
If we may be of further assistance, please feel free to call or write.
Grover C. Wrenn Director,
Federal Compliance and State Programs