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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.
August 1, 2000
W. Shaun Rainey
Kokosing Construction Company Inc.
P.O. Box 226
Fredericktown, Ohio 43019-0226
RE: Subpart "L" - Scissor Lifts
Dear Mr. Rainey:
This is in response to you September 1, 1999, letter in which you ask several questions relating to how the requirements in 29 CFR 1926 Subpart L (Scaffolds Used in Construction) apply to scissor lifts with platforms that can extend beyond the equipment's wheelbase, specifically with respect to fall protection. We apologize for the lateness of this response.
Question 1: What standards cover scissor lifts that have extendable platforms?
Answer: There has been some confusion as to which OSHA standards apply to the use of scissor lifts. The aerial lift requirements (§1926.453) incorporate by reference the definition of aerial lifts used in the American National Standards Institute (ANSI) A92.2-1969 standard. Therefore, the requirements in §1926.453 apply to equipment identified in that 1969 ANSI consensus standard as aerial lifts. The ANSI standard definition includes the following vehicle-mounted elevating and rotating work platforms: "extensible boom platforms," "aerial ladders," "articulating boom platforms," "vertical towers," and "a combination of any of the above."
Scissor lifts, including those with platforms that extend beyond the equipment's wheelbase, do not fall within any of these categories. Therefore, scissor lifts are not addressed by the aerial lift provisions of Subpart L. While there are no OSHA provisions that specifically address scissor lifts, they do meet the definition of a scaffold (§1926.451 - general requirements for scaffolds). Employers must therefore comply with the other applicable provisions of Subpart L when using scissor lifts. For example, since scissor lifts are mobile, the specific requirements for mobile scaffolds in the scaffold standard (§1926.452(w) - mobile scaffolds) must be met.
NOTE: On January 7, 1997, OSHA issued a Directive [CPL 02-01-023 (formerly CPL 2-1.23)] titled "Inspection procedures for Enforcing Subpart L, Scaffolds Used in Construction - 29 CFR 1926.450-454." In that directive, OSHA erroneously stated that "scissor lifts are addressed by §1926.453." This letter revokes and supersedes that statement; we are in the process of marking the 1997 directive that is on the Internet accordingly.
Question 2: Are employees required to be tied-off when working on a guardrail-equipped scissor lift platform that extends beyond the wheelbase of the lift?
Answer: No, neither §1926.451 or §1926.452(w) require employees to be tied-off when working from scissor lifts that have properly maintained guardrails.
If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.
Russell B. Swanson, Director
Directorate of Construction