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This program area contains information and guidance for the safety of all BNL staff, contractors, visitors, and guests on-site and off-site who work on elevated surfaces, aerial lifts, scaffolds and ladders, or are exposed to fall hazards in excess of four feet. There are many Laboratory operations that require staff to work at height. Unless the work is being performed under the rules and requirements of the Occupational Safety & Health Administrations (OSHA) Construction Safety standard (29CFR1926), working at height is defined as four (4) feet (construction is 6 feet). Fall protection requirements at BNL generally fall into the following SBMS Subject Areas: Fall Protection: OSHA 1910.23 specifies requirements for fall protection with respect to floor and wall openings, open-sided walking surfaces and stairs. The following checklists are provided as an aid to determine compliance with OSHA requirements:
Aerial Lift Safety: "Aerial Lift Do’s and Don’ts" provides a list of best practices for aerial lifts. Michael McCann of the Center to Protect Workers Rights performed statistical studies on "Deaths from Aerial Lifts in Construction" that provides information on the causes of deaths in construction. The Center to Protect Worker's Rights has also prepared an Aerial Lift Safety Hazard Alert that provides useful information on the use and safety concerns of aerial lifts. The Office of Health, Safety and Security's Operating Experience Summary (2006-12 dated November 13, 2006) provides summaries of incidents that resulted in fatalities from injuries using aerial lifts. OSHA Standard Interpretations for Aerial Lift Fall Protection Fall protection is essential for the safe operation of aerial lifts. The Occupational Safety & Health Administrations (OSHA) has provided a number of Standard Interpretations to clarify fall protection requirements. OSHA Standard Interpretations dated 08/14/2000 - " Fall protection for various lift-devices; restraint, positioning, fall arrest and rescue requirements; maintenance vs. construction examples." provides general guidance for OSHA rules. Since Aerial lifts extend from ground level, fall arrest systems may not provide adequate fall protection if there is insufficient free fall distance (typically 18½-ft). OSHA Standard Interpretations dated 01/14/2009 - "Whether a manufacturer-stipulated minimum anchor point elevation of 18½ feet precludes the use of a shock absorbing lanyard in an aerial lift" and 02/18/1999 - "Anchoring of fall arrest system to aerial lifts; fall arrest vs. restraint systems" provide specific requirements for fall protection using Aerial Lifts. OSHA Standard Interpretation dated 07/21/1998 - " Aerial lift regulations; fall protection for scissor lifts." states that scissor Lifts that are designed to ANSI 92.6, have a guard rail system that provides minimum fall protection and no additional fall protection is required. OSHA standards do not prohibit employees from exiting or entering an aerial lift basket that rests on or adjacent to an elevated surface. However, if fall protection is required (fall distances of either 4 or 6-feet), on the working surface, then the worker must be protected by approved fall protection devices (guardrails/travel restraint/fall arrestment gear). During entry to and egress from the lift, a worker may tie-off to the manufacturer’s designated anchor point and an approved anchor from the nearby structure (working surface). Specific requirements can be found in the OSHA Standard Interpretations dated 05/03/2001 - " Use of aerial lifts to transport workers to elevated workstations; scissor lifts are not covered by the aerial lift provisions." Safety Concerns when Moving or Operating Aerial Lifts The Vehicle Safety page (under the Construction Safety Program Area) provides information and guidance on the issues such as blind spots, accident prevention, site planning and the use of spotters, signalers when involved with moving and backing of typical construction vehicles and aerial lifts. 
Last Modified: April 5, 2010 |
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