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.

September 14, 2004

Mr. Dennis Vance
Dennis Vance, LLC
711 Low Gap Road
Princeton, WV 24740

Re: Is a fall arrest system required when work is done on a slide-out deck of a scissor lift?

Dear Mr. Vance:

This is in response to your e-mail dated April 25, 2004, to the Occupational Safety and Health Administration (OSHA).

We have paraphrased your question as follows:

Question: Scenario: A worker is on the platform of a scissor lift, protected from falls by a guardrail system in accordance with §1926.451(g). The worker then leaves the protection of the guardrail system and steps onto a slide-out extension of the scissor lift's platform. Is an additional fall protection system required when work is done on the slide-out deck of the scissor lift?

Section 1926.451(g)(1) requires:

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. Paragraphs (g)(1)(i) through (vii) of this section establish the types of fall protection to be provided to the employees on each type of scaffold . . . (vii) For all scaffolds not otherwise specified in paragraphs (g)(1)(i) through (g)(1)(vi) of this section, each employee shall be protected by the use of personal fall arrest systems or guardrail systems meeting the requirements of paragraph (g)(4) of this section.

We also explained in a July 21, 1998, letter to you that:

[W]hen working from an elevated scissor lift (ANSI A92.6 series), a worker need only be protected from falling by a properly designed and maintained guardrail system. However, if the guardrail system is less than adequate, or the worker leaves the safety of the work platform, an additional fall protection device would be required. [Emphasis added.]

Under the terms of the standard, a worker on the scissor-lift platform must be protected by either a guardrail system or personal fall arrest system. So, the worker on the slide-out platform must be protected by either a guardrail system or a personal fall arrest system.

If you need any 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