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 11, 2001

Mr. Jessie L. Simmons
155 Coolwood Drive
Valpariiso, IN 46385

Re: §§1926.453(a) and (b)(2), 1926.500(b), 1926.502(d) and (e); aerial lifts; fall arrest systems; positioning devices

Dear Mr. Simmons:

This is in response to your letter dated October 19, 2000 addressed to the Occupational Safety and Health Administration requesting interpretations of standards applicable to aerial lifts. We apologize for the delay in providing a response. We have paraphrased your questions below.

Question (1): Does §1926.453(b)(2)(i) through (xii) apply to self propelled boom-supported elevating work platforms, such as those dealt with in ANSI A92.5 (1992), or does it only cover elevating and rotating work platforms mounted on vehicles?

Answer: The "aerial lifts" covered by this section are those that are considered aerial lifts in ANSI A92.2-1969 (see §1926.453(a)). The ANSI A92.2-1969 standard, under 1.1.1 "Equipment Covered," states that it covers:

the following types of vehicle-mounted aerial devices used to elevate personnel to job sites above ground: (1) Extensible boom platforms; (2) aerial ladders; (3) articulating boom platforms; (4) vertical towers; (5) a combination of any of the above. These devices are made of metal, wood, fiberglass reinforced plastic (FRP), or other material and are powered or manually operated; whether or not they are capable or rotating about a substantially vertical axis.

Under section 2 of the ANSI standard ("Definitions"), "vehicle" is defined as "any carrier that is not manually propelled." So, to be within the coverage of the ANSI standard, and thus the requirements of §1926.453, the "aerial device" can be powered or manually operated, but it must be vehicle-mounted -- and the vehicle must be a "carrier that is not manually propelled."

Because the ANSI definition of "vehicle" is so broad, "vehicle" is not limited to over-the-road trucks. In answer to your question, boom-supported elevating work platforms identified in ANSI A92.5 (1992) are covered by §§1926.453(b)(2)(i) through (xii) if they are mounted on powered carriers.

Question (2): Can an employee on an aerial lift continue to use a body belt if the body belt is used to restrain the employee from falling rather than arresting a fall, such as with a personal fall arrest system? Can an employee on an aerial lift use a body belt if it is used as part of a positioning device?


The difference between a restraint system and a positioning device
A restraint system is one that prevents a worker from falling any distance. In contrast, for construction work covered by 29 CFR Part 1926 Subpart M (Fall Protection), a "positioning device" is defined in §1926.500(b) as "a body belt or body harness system rigged to allow an employee to be supported on an elevated vertical surface, such as a wall, and work with both hands free while leaning [emphasis added]." These devices are designed specifically to stop a worker from falling from a static, head-up position. Under §1926.502(e), a positioning device must limit the fall to 2 feet.

Whether body belts are permitted to be used in aerial lifts
An employee can continue to use a body belt when the body belt is used in a restraint system -- a system that prevents the worker from being exposed to any fall.

A body belt is permitted to be used in a positioning device. However, since positioning devices are defined as systems used to protect workers on vertical surfaces, positioning devices are not permitted in bucket-type aerial lifts, where the work surface is horizontal working from an aerial lift. An employee must be protected by a personal fall arrest system. Under §1926.502(d), body belts are not permitted to be used in a personal fall arrest system, and the requirement is not negated by the use of a positioning device that limits any fall to 2 feet.

Question (3): Can electricians doing construction work in an aerial lift use a positioning device to meet the fall protection requirements?

Answer: No. As explained above, in construction work, a positioning device is a device that is used while on a vertical work surface. Workers in bucket-type aerial lifts may not use a positioning device to meet the fall protection tie-off requirements since they are on a horizontal surface. Falls from such a surface can begin with the worker in positions other than the static, head-up position for which positioning devices were designed. However, these workers are permitted to use a restraint system.

If you need additional information, please do not hesitate to contact the Occupational Safety and Health Standard Administration (OSHA) [Directorate of Construction, Standards and Guidance], Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210.


Russell B. Swanson, Director
Directorate of Construction