According to a recent article published by the KHL Group, OSHA has rescinded its January 2009 letter of interpretation #20070823-7896 on the use of shock absorbing lanyards in aerial work platforms (AWP). The 2009 letter of interpretation had created uncertainty in the industry by suggesting that a manufacturer’s requirement for a minimum anchorage point elevation of 18.5 feet would prevent the use of a fall protection system (6-foot lanyard with shock absorber, full body harness) in an aerial lift. This question was previously put to OSHA due to concerns that at times the distance between the platform and the ground would be less than 18.5 feet.
The OSHA Directorate of Construction (DOC) has now rescinded the above letter of interpretation in an August 2011 memorandum to its regional administrators. ”OSHA did not ban the particular lanyard but stated, 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 height. In such cases, 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 to appropriate lanyards, for fall protection in aerial lifts. To help avoid any confusion on the issue, DOC is rescinding the January 2009 letter.”
“In rescinding this letter, OSHA is not concluding that the application described above is acceptable, rather it is clarifying that fall protection systems should not be based solely on information provided by the manufacturer, but should also take into account OSHA regulations and results of the job-specific risk assessment.,” said Tony Groat with IPAF. “IPAF believes that the primary choice for fall protection should be a restraint system, which stops the fall in the first instance.”
For more information on fall protection while using aerial lifts go to: The International Powered Access Federation (IPAF) website. http://www.ipaf.org or http://www.awpt.org