03.10.2011

OSHA rescinds lanyard interpretation

The US Occupational Safety and Health Administration (OSHA) has rescinded its January 2009 letter of interpretation #20070823-7896 on the use of shock absorbing lanyards in aerial work platforms.

The 2009 letter has created some uncertainty in the industry by suggesting that a requirement for a minimum anchorage point height of 18.5ft /5.6 metres, would prevent the use of a fall protection system (6-foot lanyard with shock absorber, full body harness) in an aerial lift.

The OSHA Directorate of Construction has now rescinded the above letter of interpretation in an August 2011 memorandum to its regional administrators, which states:“OSHA did not ban the particular lanyard but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 heights. 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.”

Tony Groat of IPAF USA, has commented on the new statement, saying: “In rescinding this letter, OSHA is not concluding that the application 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. IPAF believes that the primary choice for fall protection should be a restraint system, which stops the fall in the first instance.”

IPAF guidance states that: “When working from a boom-type work platform, it is strongly recommended that a full body harness with an adjustable lanyard be used to provide work restraint. The lanyard should be adjusted to be as short as possible (and may have a shock absorbing section if permitted by the AWP manufacturer).”

A group of industry associations, including IPAF, published an excellent guide on this subject last year, entitled a Statement of Best Practices of Personal Fall Protection Systems for Aerial Work Platform Equipment that clarifies the subject perfectly.
Click here to read more on this subject with links to the guide
Vertikal.Net fully supports the IPAF policy which strongly recommends the use of fall restraint systems in boom type platforms but not on vertical type lifts such as scissor lifts.