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.
Mr. C.K. Genge, CSP
Safety and Health Program Supervisor
Corning, NY 14831
Dear Mr. Genge:
This is in response to your letter of March 18, 1994 to Mr. Roger Clark, former Director of Compliance Programs, with regard to powered scissor-lifts. Please accept our sincere apologies for the delay in our response.
Your letter requested responses to three questions concerning the work practices that are legally required while using a properly equipped powered scissor-lift.
OSHA addresses the fall protection to be provided to employees on self-propelled scissor-lifts through the application of the general duty clause (section 5(a)(1)) of the OSH Act) because the OSHA standards do not cover such equipment. When assessing an employer's compliance efforts, the Agency considers the requirements of pertinent national consensus standards. In this case, OSHA has referenced ANSI/SIA A92.6-1990, Self-propelled Elevated Work Platforms.
Following are your specific questions and our responses, consistent with ANSI/SIA A92.6-1990:
When using a powered scissor-lift in an elevated position, is it legally required to use fall protection devices (i.e., belt or harness with attached safety line)?
Section 4.12.2 of the subject ANSI/SIA standard requires that platforms have guardrail systems and sets criteria for those systems. In addition, section 7.11.1 requires that employees maintain a firm footing on the platform floor while working thereon. The Agency believes that operations which comply with those requirements will adequately protect affected employees from fall hazards.
Therefore, OSHA would require the use of a personal fall arrest system (PFAS), only where the employer was not following the above-cited ANSI/SIA provisions. The Agency would assess the adequacy of a PFAS through reference to Appendix C of §1910.66, Powered platforms.
When using a powered scissor-lift in an elevated position, if there are no physical obstructions, can the operator legally drive the powered vehicle from one place to another without lowering the lift (i.e., while changing light bulbs or fluorescent light ceiling mounted fixtures in a warehouse)?
The subject ANSI/SIA standard addresses requirements for elevated driving in Section 7.11.14, and manufacturer testing (movement of the vehicle while the scissor-lift is elevated) in Section 4.7.3. Section 7.11.14(2) describes ideal conditions, where the driving surface is clear from obstacles, debris, drop-offs, holes, depressions, ramps and other hazards to ensure safe elevated travel. Thus, if those provisions are followed, the self-propelled elevated work platform may be driven without lowering the platform.
When using a scissor-lift in an elevated position and other methods (i.e., extension ladders) are determined to be more hazardous, would it be legally permissible to kneel or sit on a small platform (i.e., 211 x 911 scaffold grade plank) resting and secured to the midrails of the lift.
This practice is not acceptable, since it is clearly unsafe and would jeopardize the safety of the employees. Extending the height by means of external devices such as platforms would render the stability test of the scissor-lift invalid. This position is consistent with Section 7.11.1 of the above cited ANSI/SIA standard which states, "Use of planks, ladders, or any other device on the aerial platform for achieving additional height or reach shall be prohibited."
Thank you for your interest in occupational safety and health. If you need further assistance, please contact Alcmene Haloftis of my staff at 202-219-8031.
John B. Miles, Jr., Director
Directorate of Compliance Programs