Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

October 10, 1997

Mr John A. Dahmer
Wisconsin Electric Power Company
231 W. Michigan
P.O. Box 2046

Dear Mr. Dahmer:

This is in response to your January 3 letter requesting interpretation of the electric power generation, transmission, and distribution standard 29 CFR 1910.269. Specifically you requested clarification of the fall protection requirements in §1910.67 Vehicle-mounted elevating and rotating platforms and paragraph 1910.269(g)(2).

Fall protection equipment used in aerial lifts for work performed under §1910.269 must meet the requirements of either paragraph 1910.269(g)(2)(i) or (g)(2)(ii). A body belt and lanyard may be used as fall protection equipment for such work; however, after January 1, 1998, this equipment may only be used as work positioning equipment. (Work positioning equipment as used in an aerial lift can also be rigged as a restraint system.)

Paragraph 1910.67(c)(2)(v) requires employees working from aerial lifts to wear a body belt with a lanyard attached to the boom or platform. A fall arrest system meeting paragraph 1910.269(g)(2)(i) may also be used as fall protection equipment for employees working from aerial lifts. If work positioning equipment is being used to meet aerial lift provisions, paragraph 1910.269(g)(2)(ii), which adopts §1926.959 by reference, must be met. Personal fall arrest equipment must meet paragraph 1910.269(g)(2)(i), which requires fall arrest equipment to meet 29 CFR 1926 Subpart M. (The note following paragraph 1910.269(g)(2)(v) applies only to that paragraph. It does not apply to the remainder of paragraph 1910.269(g)(2).) A body belt and lanyard combination is considered to be work positioning equipment if the employee it is protecting can free fall no more than 2 feet (0.6 meters). For aerial lift work covered by §1910.269, body belts would only be acceptable after January 1, 1998, if they are attached to a lanyard that limits the free fall distance to no more than 2 feet.

Thank you for your interest in employee safety and health. If we can be of further assistance, please contact the Office of General Industry Compliance Assistance, Mr. Ronald J. Davies, telephone # (202) 219-8031, extension 110.


John B. Miles, Jr., Director
Directorate of Compliance Programs