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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.
October 23, 2002
C.Y. Concepts, INC.
440 Stone Road
Rochester, N.Y. 14616
Re: Whether workers may stand on scaffold guardrails; anchor points; §§1926.450, 1926.502(d).
Dear Mr. Youney,
This is in response to your August 6, 2002, letter to the Occupational Safety and Health Administration (OSHA). We apologize for the delay in answering your inquiry.
Question: Is it permissible to allow workers to stand on boom lift1 guardrails or scissor lift guardrails in order to perform work if they use a personal fall arrest system?
The answer is no for aerial lifts. Section 1926.453(b)(2)(iv) states that "employees shall always stand firmly on the floor of the basket, and shall not sit or climb on the edge of the basket or use planks, ladders, or other devices for a work position."
The requirements of 29 CFR Part 1926 Subpart L (Scaffolds) applies to scissor lifts. There is no single provision in the scaffold standard that states that this practice is prohibited. However, as a practical matter, it is unlikely that all the requirements of the scaffold standard could be met while engaging in this practice.
Section 1926.451(a)(1) requires, in general, that each scaffold and scaffold component "be capable of supporting, without failure, its own weight and at least four times the maximum intended load applied or transmitted to it." Also, one of the requirements of §1926.451(a)(6) is that scaffolds be loaded in accordance with its design. Section 1926.451(f) prohibits a scaffold from being loaded in excess of the maximum intended loads or rated capacities.
To meet these requirements with employees standing on the guardrails, the scaffold would have to be designed so that the load imposed by employees climbing onto and standing on the guardrails (which include eccentric loads) would be within the capacity of the guardrail, all other scaffold components, and scaffold as a whole, with a safety factor of 4:1. Scaffold guardrails and associated components typically are not designed to handle such loads.
Secondly, if the employees were to stand on the guardrail, it would be considered a scaffold platform - the definition of a scaffold platform is "a work surface, elevated above lower levels...." The guardrail would then have to meet the requirements in §1926.451(b) (scaffold platform construction).
One of those requirements is §1926.451(b)(2), which states that, subject to some exceptions, scaffold platforms must be at least 18 inches wide. Under §1926.451(b)(2)(ii), narrower platforms are allowed only where the employer demonstrates that they cannot be at least 18 inches. Before an employer would be allowed to use a guardrail as a work platform, it would have to demonstrate that the width of the guardrail (the top rail's diameter) was the widest the platform could be. Since the guardrail would be on a scaffold, and the scaffold would be considerably wider than the top rail's diameter, the employer would not normally be able to make that showing.
Use of personal fall protection would not be a substitute for compliance with these scaffold requirements - these plus the fall protection requirements2 must be met. Note that §1926.502(d)(23) prohibits personal fall arrest systems to be attached to guardrails systems. Therefore, the system would have to be anchored to either the scissor lift or an adjacent structure.3
If you need any further clarification on this subject, 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
1 We assume "boom lifts" is a reference to aerial lifts. [ back to text ]
2 Section 1926.451(g)(1) requires that each employee on a scaffold more than 10 feet (3.1 m) above a lower level shall be protected from falling to that lower level. Depending on the type of scaffold, personal fall arrest and/or guardrails is required. Most scissors lifts are covered by §1926.452(w), Mobile scaffolds, and guardrails or a personal fall arrest system in absence of guardrails are used to protect employees from falls. [ back to text ]
3 OSHA standards permit fall arrest systems to be anchored to scissor lifts as long as the anchorage requirements in §1926.502(d) and the requirements of the scaffold standard are met. Under §1926.451(a)(1), (a)(6) and (f), if the personal fall protection system were anchored to the scissor lift, the scissor lift would have to be able to sustain the loads imposed by an arrested fall, with a 4:1 safety factor. [ back to text ]