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.

August 18, 1995

Mr. Jerald Wright
Safety Coordinator
Kimberly-Clark Corporation
32 Smyth Avenue
Hendersonville, North Carolina 28792

Dear Mr. Wright:

This is in response to your letter of June 29 to the Occupational Safety and Health Administration (OSHA) in which you wanted to confirm your understanding of several fall protection issues relating to scissors lifts and aerial lifts.

We concur that neither the OSHA standards nor the applicable ANSI standard (A92.6-1990) require employees on scissors lifts to tie off while on platforms equipped with guardrails. If guardrails are removed or ineffective, then other means of fall protection would have to be provided.

The OSHA standards do, however, require employees in aerial lift baskets to be tied off to protect them from being bounced out of the basket or from climbing out of the basket.

If you have any questions, please call me or Dale Cavanaugh of my staff at (202)219-8136.


Roy F. Gurnham, P.E., J.D.
Office of Construction and Maritime
Compliance Assistance