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Does a manufacturer required anchor point elevation of 18½ feet preclude the use of a shock absorbing lanyard in aerial lifts? On January14, 2009 Noah Connell, Acting Director, Directorate of Construction for OSHA, issued an interpretation as to whether a manufacturer-stipulated minimum anchor point elevation of 18½ feet precludes the use of a shock absorbing lanyard in an aerial lift.

He stated in that interpretation that “…section 1926.502(d)(16)(iii) requires a personal fall arrest system to prevent the employee from contacting a lower level. The lanyard you describe would not meet that criterion when the aerial lift's work platform is at heights less than 18½ feet. Even if the working level of the aerial lift will ultimately be higher than 18½ feet, §1926.453(b)(2)(v) requires fall protection for employees in aerial lifts at lesser heights as well.4 Since the fall protection system you describe would not meet the requirements of §1926.502(d)(16)(iii) under these conditions, it would be prohibited.” (emphasis added). See the entire interpretation at

This interpretation is the first written prohibition against tear away lanyards that allow an 18 ½’ fall. What Mr. Connell did not explain in his interpretation, and which I believe needs further explanation, is that the manufacturer’s requirement of over-the-head tie off points (see instructions on any safety harness in your possession) also precludes the use of these types of lanyards in most other fall protection situations as well. This interpretation only explains half of what you need to understand.

Please study my Fall Distance Comparison and you will see that since buildings are normally built in 10’ increments, a safety harness that will allow an 18 ½’ fall will also allow you to contact the lower level. Especially when working in plant situations where the structure has already been built, how are you going to tie off over the top of your head?

Some people will tell you to hook onto a retractable. What manufacturers have not told you is you can only be 18” from the center of a retractable; anything more than that is out of federal compliance. Explanation: You have 18” plus a two foot drop with this equipment. That is a 3 ½’ drop which is already 1800 lbs plus of force on the body and you still have to be tied off over the top of your head. If you bend over to pick up a tool, you’re already out of compliance. Be not deceived! Retractables were designed to use on ladders for ascending and descending only!!!

When the Fall Distance Comparison and the Standard Interpretation are viewed in conjunction with each other you will see where many misconceptions in the industry are coming from. I believe that a close study and understanding of both of these documents is critical for the safety of employees who are required to work from an aerial left or use an aerial lift to reach their work area. And remember, this is not only for aerial lift situations. Look at your hazards with this information in mind and you’ll see exactly what I’m trying to tell you.

The unit that I build does not need an over-the-head tie off point. I was an ironworker for over 20 years and if I couldn’t sit down on a beam and tie off at my waist level and be in federal compliance, that tool is useless. See the Ironworkers article on my website at Mr. Miggliaccio is not only the Chairman of the Building Trades Council in Washington, D.C., he is now also the Chair of the ACCSH Committee. He states that we eliminate more recognized hazards (OSHA violations) than you can count on two hands. These are direct violations of the General Duty Clause that you could be fined and possibly prosecuted under. We have two UL certifications; one to the federal fall protection standard and one to the ANSI recommendations. Underwriters Laboratories is a true third party testing facility and you should consider almost everything you purchase has a UL label which certifies that it is safe and meets federal requirements in order to be sold in the U.S.A!!!

I would very much welcome any comments or questions concerning this issue and look forward to talking with everyone about it. It has always been our main goal to get this critical issue before as many people as possible and we work strenuously to accomplish that. If you have colleagues that are not members here I would appreciate it very much if you would provide them with this information. We’re all about making sure that everyone goes home to their family every day. When you examine the evidence provided here you’ll know that we have spoken the truth, the whole truth and nothing but the truth and the truth will set you free from the leading cause of death and critical injury in the American Workforce!

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Replies to This Discussion

Im glad to read your sharings, im also, in a construction business and you have a poin in true value of safety.


Lorenzo " Bobby" R. Abeleda
Let me know if there's anything I can help you with while you are in the States. Thanks for your reply.

Mark Dennington
(318) 635-5454
As I tell folks the "A" in PFAS stands for "arrest" which means stops - before contact with a lower level. Great article. Great resources. Thanks.
Find more about OSHA Fall Protection standard the fast and easy way at Click on Construction Industry link.
Hello Mark,
I ventured across your patented fall arrest harness about a year ago. Nice product theory. I appreciate your interest concerning worker safety in the construction category, and the research that you ventured.

I would like to comment on your concerns of fall protection while in an aerial lift. It is my personal understanding (my own interpretations of Regulations, and the scope of the OSHA Regulation which is to be interpreted with employee safety as a focus) that the fall protection is provided by the guard-rail system surrounding the aerial lift platform. The requirement for a lanyard and harness is incorporated to maintain the user within the basket, as a restraint device, to prevent being tossed out of the basket.

This would require a shorter lanyard of only 4' (quick guess), since the users feet will always be on the basket floor. With this shorter distance of fall (the length of remaining lanyard hanging over guardrail system) the impact on the human body would be even less than the 1800# force (claims of some of the retractable device manufacturers with quicker response times) and would eliminate the need for a deceleration device. I believe that a retractable device could be implemented in this scenario, to keep the lanyard length to a minimum (depending on the size of the basket of the aerial lift).

You made some other interesting statements concerning the retractable lanyard devices that I will research before commenting further. Apparently you have done more research than my assumptions and interpretations have implanted in my mental knowledge base.

Thanks for your post,
Glen Givens

Thanks for your post. I understand what you are saying but please call me for further discussion on this subject. My office number is 318-635-5454 extension 2. I look forward to hearing from you.

Mark Dennington

I would be glad to have this conversation. What time zone are you in? Is there a time during the day that would be better than others?

There are different tie off requirements for a "connector" than a "steel-worker", maybe that is the attitude that is needed for truss setting?

Glen Givens
Mark, Lately I'm been working on military bases and following EM385-1-1 A.C.O.E. Personnel working from a basket must be restrained so that they can not climb out of the basket Section 21.J. 05 – “Aerial lift Equipment: Workers shall be anchored to the basket in accordance with manufacture specifications and instruction. Lanyards used shall be sufficiently short to prohibit worker from climbing out of basket.” A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift. My experiences have been if workers are working from "Aerial work platform" they shall wear Fall Restraint.
Thanks for the info and the commitment to reducing injuries on the job.

Tell me, what kind of forces are generated by your system on a 310 lb worker in a 6' free fall?
since you have eliminated the traditional tear-away shock absorber, what kind of clearance is required for your deceleration device?
What is the MSRP for your system?
How often do you test this product for OSHA and ANSI compliance as a part of your quality control ( many units are manufactured before you re-test to ensure quality and safety on batches)?
We have UL certifications to both federal and ANSI which shows the force generated and fall distance. As you may know UL has a stringent policy for testing and retesting equipment once its been rated. They visit our manufacturing facility on a quarterly basis and retest on a yearly basis. You will not find any other manufacturer of fall protection with a UL certification. I am attaching both of these for your review. I would also like to email you some information. If you will send me an email to I will forward that information, including a price sheet for you. Don't forget to check out my website at I look forward to hearing from you.
Thanks Mark


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