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 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTER...
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 www.DenningtonSafetySystems.com
. 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!