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• Citation eventually withdrawn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 manufacturer’s instructions, which stipulated a minimum anchor point height of 18.5 feet, that it was likely that the lanyard’s 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 systems…shall 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 representative’s 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)