BUCKET TRUCK FALL PROTECTION
WHAT FALL PROTECTION DEVICES
ARE ACCEPTABLE
BY
FEDERAL OSHA
Started with a letter of interpretation - 2009
Contractor was cited
EEI / IBEW met with OSHA several times
Citation eventually withdrawn
Contractor had fatality OSHA Denver Region
Contractor was cited
Contractor / OSHA settled
Contractor now using retractable lanyards in bucket truck
OSHA Memo to field August 2011
BUCKET TRUCK FALL PROTECTION
BUCKET TRUCK FALL PROTECTION (August 2011 MEMO)
OSHA did not ban the particular lanyard, but stated that, based on the manufacturers instructions, which stipulated a minimum anchor point height of 18.5 feet, that it was likely that the lanyards use would not comply with OSHA standards at lower heights.
In that case, use of the lanyard below 18.5 feet would apparently not provide adequate fall protection. This determination has raised questions about the use of body harnesses, typically married with appropriate lanyards, for fall protection in aerial lifts. To help avoid any confusion on the issue, DOC is rescinding the January 2009 letter, #20070823-7896.
Employers must ensure that employees using personal fall arrest systems while working on aerial lifts at heights six feet or more above a lower level comply with 1926.502(d) of subpart M, specifically: Personal fall arrest systems, when stopping a fall, shall: (iii) be rigged such that an employee can neither free fall more than 6 feet (1.8 m), NOR CONTACT ANY LOWER LEVEL. [1926.502(d)(16)(iii)]
BUCKET TRUCK FALL PROTECTION (August 2011 MEMO)
BUCKET TRUCK FALL PROTECTION
Anchorage level
Back of truck
Ground level
OSHA 1926.502(d) Personal fall arrest systemsshall be rigged such that an employee cannot free fall more than 6 feet nor contact any lower level
TOTAL FREE FALL DISTANCE
As has been the Agency's longstanding policy, an employer may comply with OSHA's fall
protection requirements for aerial lifts in one of three ways:
Use of a body belt with a tether anchored to the boom or basket (fall restraint system),
Use of a body harness with a tether (fall restraint system), or
Use of a body harness with a lanyard (fall arrest system).
BUCKET TRUCK FALL PROTECTION
BACKGROUND
Recent citations surrounding the use of a harness and shock absorbing lanyard
while working out of a bucket has caused a concern among industry and
labor representatives regarding how to comply with the regulations on fall
protection
Aerial Lift Fall Protection Summit in DC (December 2011)
OBJECTIVE
The Summit's primary objective was to bring together OSHA, labor, end users, manufacturers of fall protection equipment, and manufacturers of aerial lift devices to discuss the regulations that apply, how they are to be interpreted, how fall
protection equipment and aerial lifts are designed and expected use requirements for the purpose of
a better understanding of the roles and responsibilities of each party in the fall protection
arena
Aerial Lift Fall Protection Summit in DC (December 2011)
KEY QUESTIONS
What fall protection device(s) will OSHA accept as compliant?
Does contact any lower level include tree limbs, cables, or conductors?
Is the back of the truck considered a lower level? Does the fall protection equipment have to be rigged
such that the employee cannot come out of the basket?
Are there fall protection devices on the market that can meet OSHA expectations for compliance?
Can the group as a whole work together to come up with a workable solution for all involved?
Aerial Lift Fall Protection Summit in DC (December 2011)
OUTCOMES Follow up conference call with OSHA / EEI / IBEW
OSHA provided accident data to review
Data determined not relevant to industry / issues
Determined no data exists that is relevant
OSHA questioned why August 2011 Memo was not satisfactory to address issues
OSHA asked where the problems existed
OSHA said they would contact regions
No additional activity
Aerial Lift Fall Protection Summit in DC (December 2011)
