Scissor Lifts as Mobile Scaffolds, Not Aerial Lifts

The Safety Blog’s recent post on scissor lift’s fall protection caught the attention of our readers, especially one who particularly commented on the regulations lifted from 29 CFR 1926.453, Aerial Lifts. He said that 1926.453 refers to boom lifts, not scissor lifts.  He added that scissor lifts are regulated as scaffolds.  (Note : Thanks to Michael McCann @ The Center for Construction Research and Training, for this catch!)

On this note, The Safety Blog stands corrected.  Indeed, scissor lifts are regulated by OSHA as mobile scaffolds and not as aerial lifts.  At this point, let me show you excerpts from some of OSHA’s directives, standard interpretations and regulations referred to that brought clarity to the issue at hand.

In an OSHA directive entitled Inspection Procedures for Enforcing Subpart L, Scaffolds Used in Construction – 29 CFR 1926.450-454, paragraph K.9.b reads “Scissors lifts are addressed by 1926.453 – Aerial Lifts, not by 1926.452(w), mobile scaffolds.”  If we will just consider this statement, we may just refer solely to 1926.453 to learn about the fall protection requirements of scissor lifts.  However, if we will read a fitting standard interpretation from OSHA, it will be clear to us that only aerial lifts meeting the design and construction of ANSI (American National Standards Institute) A92.2 or Vehicle Mounted Elevating and Rotating Work Platforms are actually addressed by 1926.453.  Other mobile lifts not meeting ANSI A92.2 such as Self-Propelled Elevating Platforms (ANSI 92.6) are instead covered by 1926.452, Additional requirements applicable to specific types of scaffolds, where 1926.452(w) specifically deals with mobile scaffolds. We can also refer to 1926.451 which is the General Requirements of scaffolds.

At this point, I would like to reiterate that scissor lifts are regulated as mobile scaffolds and not as aerial lifts. Now, if we would like to know the fall protection regulations of scissor lifts, we need to look at 1926.451.  Again, fall protection is not required.  Instead, personal fall arrests systems can be used or guardrail systems (with closing gate or latch chain) that meet the requirements of 1926.451 must be installed on all open sides and ends of platforms.  However, if the worker leans, stands or leaves the lift’s platform, an appropriate fall protection may be needed.

The tips and reminders on how to avoid falls from scissor lifts from the referred blog entry may still be observed.  Though the ones with reference to 1926.453 do not apply to scissor lifts, some of them can help in reducing the risk of falls is scissor lifts and in scaffolds as well.

The Safety Blog would like to thank its readers for sending in their comments and for contributing to a healthy discussion of safety issues.

READER INQUIRES ABOUT FALL PROTECTION ON SCISSOR LIFTS

We at Safety Blog value our readers and make it a point to consider their needs when coming up with blog articles. In this post, we will answer a reader’s query on scissor lifts.

Reader asks: “There seems to be confusion about wearing fall protection on scissor lifts. Would it be possible for you to do an article about this?”

The Safety Blog answers: “Dear Reader, thank you for your query. You may or may not wear fall protection on scissor lifts. Here’s the full article.”

Scissor lift is one kind of aerial lift mainly used in construction and the general industry. If we closely study OSHA’s regulations on aerial lifts, we will see that fall protection is not required. Instead of fall protection, OSHA requires a guardrail system that is properly designed and maintained. However, if the guardrail system is not enough or if the worker leaves the safety of the lift’s platform, OSHA requires an additional fall protection device. In such cases, you may use a personal fall arrest system.

Depending on the [legal] activity on the aerial lift or when you deem it necessary to use a fall protection system, by all means, please use one.

Some reminders on scissor lift use:

1. Follow company policy on the operation of the lift.

2. Be familiar with OSHA regulations. Apply them. Take note that aside from following the minimal federal regulations requirements, you should also follow your state and local regulations.

3. Be trained both in the classroom and in the actual workplace. Keep a record of your trainings.

4. Participate in workshops and seminars. Some of these are free.

5. Consult the scissor lift’s manual for specifics.

6. Wear the appropriate personal protective equipment like hard hats, safety shoes, safety gloves, reflective vests or clothing, safety glasses and hearing protection. Maintain it well.

7. For more information, consider the aerial lift training kit offered by Safety Services Company.

To avoid falls from the scissor lift:

1. Make sure that you have inspected the machine before using it – mechanical parts, batteries and hydraulics. Sudden jerking, tipping and even stopping might prove to be dangerous.

2. Check all controls each day to make sure they are in safe working condition. [29 CFR 1926.453(b)(2)(i)].

3. Check the surface of the ground. Is it hard enough? Is it sloped and slippery? Are there ground depressions, holes and drop-offs?

4. If working on an incline, install wheel chocks if they can be safely installed [29 CFR 1926.453(b)(2)(vii)].

5. Inspect the work environment. Is it free from obstructions? Is there enough space for the machine to move around? Are there overhead hazards?

6. What’s the weather condition? Is it too windy? Is there lightning?

7. Do not overload the lift [29 CFR 1926.453(b)(2)(vi)].

8. Make sure that there is even distribution of workers, tools and other equipment across the platform.

9. Wear a body belt and a lanyard attached to the basket [29 CFR 1926.453(b)(2)(v)].

10. Close all gates. Keep all chains and rails secured. Do not exit the platform while it is elevated. Do not climb out onto the rails.

11. Stand firmly on the floor of the platform. Do not sit nor climb on the edge or use planks, ladders and other devices for a work position [29 CFR 1926.453(b)(2)(iv)].

12. Remember to hold on while you are being elevated. Do not play around while on top.

13. Always face the direction of your travel.

14. Do not allow someone to lean a ladder against the lift.

15. Maintain your machines well. Have it checked by authorized persons only.

Working in heights while riding aerial lifts is quite dangerous. It is therefore very important to assess your work activities and follow all safety precautions before carrying on.