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BUCKET TRUCK FALL PROTECTION - Es pdf files/EEI Spring 2012/CKelly... · PDF fileBUCKET TRUCK FALL PROTECTION (August 2011 MEMO) OSHA did not ban the particular lanyard, but stated

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  • 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    Citation eventually withdrawn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)

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