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.

September 5, 1995

Mr. Sidney Freedman
Director, Erection Safety Services
Precast/Prestressed Concrete Institute
175 West Jackson Boulevard
Chicago, Illinois 60604-9773

Dear Mr. Freedman:

This is in response to your letter of May 23 to the Occupational Safety and Health Administration (OSHA) in which you requested an interpretation relative to ingressing and egressing an elevated manlift at an elevated level.

You asked if employees could tie off to aerial lift baskets during entry to and exit from the baskets where the baskets rest on an elevated floor or roof or where the basket rests at the edge of an elevated floor or roof. You noted that OSHA standards do not address this issue in 29 CFR 1926.556, and ANSI standards and manufacturer's literature also do not cover this issue. You asked if we agreed with the Steel Erection Negotiated Rulemaking Advisory Committee (SENRAC) workgroup, which on May 10-11, 1995, made a proposal which states:

"SUSPENDED PERSONNEL WORK PLATFORMS- Personnel boxes complying with the regulations can be used either to gain access onto the structure or as working platforms. When used for access, the box should, where possible, be landed on a firm, level surface which is wide enough to fully support it. People should enter or leave the box one at a time and the alighting area should allow them to climb in and out of the box easily and safely. There should also be a safe means of access to the place of work from the box. When boxes are used as a working platform for making connections on an open framework, people should not attempt to leave the box at height unless a safety harness is used by each steel rigger to secure themselves to the box or structure."

We agree that harnesses should be worn anytime an employee is exposed to a fall of six feet or more while alighting from or climbing into a basket. Although the SENRAC statement is intended for crane or derrick suspended personnel platforms, believe it is appropriate for ANSI A92 types of equipment also.

OSHA's new fall protection standards, 29 CFR 1926.500-503, require that harnesses rather than body belts be used for fall arrest beginning January 1, 1998. In addition, the criteria listed in the fall protection standard should be followed with regard to items such as anchorage support and maximum arresting force on an employee should a fall occur. The manufacturers of the lifts should also certify that the aerial lifts are designed not to tip over should a person tied to the lift fall from the lift from a position on top of the manbasket guardrail. If this cannot be assured, then the person should tie off to an appropriate nearby structure during entry to and egress from the lift.

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