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.

May 13, 1999

Ms. Laura Angelo
Safety Director
Wiese Planning & Engineering
1445 Woodson Road
St. Louis, Missouri 63132-2580

Dear Ms. Angelo:

This is in response to your letter of March 24, requesting compliance assistance from the Occupational Safety and Health Administration (OSHA) regarding the Vehicle-mounted elevating and rotating work platforms standard 29 CFR 1910.67.

Section 1910.67 applies to vehicle-mounted elevating and rotating work platforms. Under this standard, aerial devices (aerial lifts) must meet the applicable requirements of the American National Standard for "Vehicle-Mounted Elevating and Rotating Work Platforms," ANSI A92.2-1969. In 1910.67, a vehicle is defined as "Any carrier that is not manually propelled." Therefore, 1910.67 would cover self-propelled boom-supported elevating work platforms. Boom-supported elevating work platforms are also covered by the American National Standard for "Boom-Supported Elevating Work Platforms," ANSI A92.5. Employers are encouraged to comply with current versions of national consensus standards as long as the current version provides at least the level of safety and health otherwise provided by complying with applicable OSHA standards. Under the de minimis violation policy, OSHA will recognize compliance with ANSI A92.5-1992 for this type of equipment. De minimis violations are violations of OSHA standards which have no direct or immediate relationship to safety and health and will not be included in citations.

Safety Standards for Fall Protection in the Construction Industry; Final Rule; August 9, 1994, revised the OSHA construction industry safety standards which regulate fall protection systems and procedures. In addition, the final rule made one change to a provision in the OSHA standards for general industry. In particular, 1910.269, Electric Power Generation, Transmission and Distribution; Personal Protective Equipment contains a requirement in paragraph (g)(2) that personal fall arrest equipment meet the requirements of Subpart M of Part 1926. That provision [(g)(2)] was revised to require the equipment to meet the requirements of revised Subpart M of Part 1926. Fall protection requirements specified at 1910.67 have not been revised. 1910.67(c)(2)(v) requires the use of a body belt, however, the use of a body harness will also meet compliance with this standard.

Thank you for your interest in occupational safety and health. If we can be of further assistance, please contact Wil Epps of my staff at (202) 693-1850.


Richard Fairfax, Director
Directorate of Compliance Programs