The construction industry in the US, Canada and beyond has been demanding the use of aerial work platforms to access work at height – outside the platform. Manuals and current guidance do not allow the practice without permission and instructions from the manufacturer, but many workers don’t view the process of seeking permission as a practical and timely solution to the problem.
In reality, the practice of exiting the platform at height does happen on jobsites because it’s sometimes the safest way to carry out temporary work at height. Other times it occurs unsafely, with no instructions or guidance to follow. The questions up for debate are whether the practice of entering/exiting an aerial work platform at height is a reasonable way to accomplish a task, and if so, what can be done to ensure it’s done in the safest possible manner?
Jenny Lescohier: Why is entering/exiting from an elevated AWP such an issue?
John Rickert: There’s a certain amount of awkwardness built into entering or exiting an aerial work platform at height. On the re-entry at height, there’s no control if there’s nobody in the machine. Unless there’s some kind of setup for 100-percent tie-off, the user is not only getting off the lift onto what might be a changing work area, he’s also doing a mildly disorienting thing by going underneath a rail. That being said, once you tie off to something outside the lift, now the user is vulnerable if something happens with the lift. Without specific instructions on how the practice should be done, it’s just sort of done off the cuff.
I’ve seen scissor lifts being used as an elevator or a material lift on a job. I’m concerned that they’re jumping genres; going from something that was made for powered access, and then changing the actual intent of the design. This lends itself to a cowboy mentality. The user is trying to use this as a way to accomplish a task without putting sufficient planning into it.
Tony Groat: If the machine isn’t specifically approved for entering or exiting – and typically they are not – then the application is not approved. But current language says entering and exiting at height can be done, “If permitted by the manufacturer.” The construction industry looks at the equipment as one of the more safe ways to provide access in many situations. So, the complaint in the industry is that we don’t provide guidance and for the most part, prohibit the use of aerials in that application, and they’re looking for standards to provide guidance for this.
Currently, when people are doing this, they do have a cowboy mentality, which is: “find a way to get it done.” Here’s a machine which is typically not used as an elevator. It’s a work platform, and now we’re getting in and out of it. How can we do this properly? If we open this door, are we suddenly saying these devices can be used as elevators?
Damon Bonneau: This is not a new area for OSHA. There’s a letter of interpretation from 2001 where someone asked if OSHA had standards that prohibit exiting aerial lifts at height and OSHA’s reply was no, the standard doesn’t do that. However, if you come out of that lift, then you fall under another standard: Subpart M for fall protection or Subpart R for steel erection. Once you exit the aerial lift, then you immediately fall under the requirements of Subpart M that says if you’re above 6 feet, you have to have fall protection. We don’t have a standard that prohibits leaving that lift, but we do have standards that say if you’re working at height, then you have to be protected from falls.
Chuck Harvey: Employers must ensure they do a hazard analysis for all their activities. In this case, that analysis should include items like site conditions, possible electrical hazards, proper equipment setup, and fall protection training and equipment, to name a few. There was a case I found in our files involving a fatality where somone got off an aerial lift, walked onto another surface and fell through a ceiling sky light. Obviously they had not done a complete analysis of the other surface. That’s where OSHA’s concern is. Where are people getting hurt by this? There’s no specific standards, but in these cases, employers were cited under OSHA’s general duty clause. The employer has the responsibility to keep their people safe.