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 http://www.osha.gov.

September 19, 1995

Mr. Gary Clifford
4027 Woodland Drive
Lake Carmel, New York 10512

Dear Mr. Clifford:

This is in response to your letter of December 28, 1994 to the Occupational Safety and Health Administration (OSHA) in which you had comments concerning tying off on aerial lifts. You felt that tying off to a substantial overhead object may be safer than tying off to the "boom or basket," as required under 29 CFR 1926.556(b)(2)(v).

As you probably know, 29 CFR 1926.556(b)(2)(iii) prohibits belting off to an adjacent structure while working from an aerial lift. The purpose of being tied off to the boom or basket of the lift is to keep the employee from being bounced out of the lift during travel and to prevent the employee from being able to climb out of the lift. We disagree that tying off to an adjacent structure would be safer. Among other problems, the employees would have to disconnect and reconnect their lanyards each time the aerial lift was moved, and employees could forget to disconnect their lanyards from the adjacent structure prior to moving the lift.

We appreciate your comments and hope that we have been responsive to your concerns. If you have any questions, please call me or Dale Cavanaugh of my staff at (202)219-8136.

Sincerely,



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