This is a two-part blog series regarding fall protection in Aerial Lifts vs. Scissor Lifts. In Part I, we explored the difference between the two lifts as well as the types of fall protection utlilized with each. Now in Part II, we will discuss problems that arise with tie-off on scissor lifts as well as personal fall protection.
Why Not Tie Off?
Some employers have made it a requirement for workers to tie off when using scissor lifts. There are several problems with this self-imposed requirement, including:
- Freedom of Movement
- The Peltzman Effect
Freedom of Movement
One argument against the scissor lift tie-off requirement is it restricts the user’s range of movement. The length of the typical scissor lift platform affords a wide range of movement for the lift users. They may walk freely from end-to-end and still be protected from falls by the rails. If scissor lift users are required to use personal fall protection equipment, then their range of movement is limited to the length of their lanyard. A six-foot lanyard attached to a deck-mounted anchor would significantly limit the distance the user could travel. To compensate for this problem, I have seen some employers who require tie-off, install steel rings, carabiners or other devices onto rails to allow the users to move along the length of the platform as the anchor device slides along the rail. Since 1926.502(d)(23) prohibits personal fall arrest systems to be attached to guardrail systems, this would be a violation.
The Peltzman Effect
Professor Sam Peltzman with the Booth School of Business at the University of Chicago, theorized in the 1970’s that regulating safety through required safety interventions such as the use of seat belts in cars, or the requirement of crumple zones in automobile design, was actually counterproductive as it provides the operator with a sense they are safer and thus their behavior becomes more reckless.
Applying Peltzman’s hypothesis, requiring the scissor lift user to wear personal fall protection may lead the user to feel it is safe to over-extend, climb onto the rails or even step outside the guardrails.
The problem, should workers do this, is two-fold. First, it would be a violation to step up onto the rails because by definition the rails would then be considered a working platform which, by definition, must be a minimum of 18 inches wide. Secondly, the vast majority of scissor lift users who use supplemental fall protection use a personal fall arrest system (PFAS) consisting of a harness and a six-foot shock absorbing lanyard or a six-foot fixed lanyard in conjunction with a rip stitch deceleration package. Both the shock absorbing lanyard and the deceleration package will deploy to add an additional (in most cases) 3 ½ feet to the fall distance. Taking other factors into account, a worker using such equipment may have a fall distance between 15 and 18 feet depending on where they secure the lanyard. Therefore, a worker who falls from a scissor lift platform which is stationed 12 feet above the floor is going to hit the floor before his PFAS will stop him.
Requiring workers to tie off when using a scissor lift may, under some circumstances, make it difficult at best for workers to perform the job and still comply with the company policy, thus leading the workers to circumvent the policy. If the employer creates a rule requiring scissor lift users to tie off, then that becomes an OSHA requirement since employers are expected to enforce their own rules. So if the worker, for whatever reason, opts to work from the lift without using the prescribed fall arrest equipment, in violation of company policy, OSHA may issue citations under the general duty statute.
Personal Fall Protection
It is much safer, not to mention easier, to prevent the fall from happening than it is to arrest it after the fact. Fall restraint uses a belt or harness and a fixed length lanyard, which is short enough to prevent the wearer from being able to fall. Fall arrest systems, on the other hand, are designed to arrest a worker’s fall. Whenever using fall arrest, there are additional considerations that must go into the equation:
- Task planning is much more complex and crucial to safety of the worker.
- A worker could strike something below the lift and be injured during the fall.
- A worker could swing due to the pendulum effect and strike nearby objects.
- Fall distance must be calculated to assure the height from which the worker might fall is greater than the length of the PFAS after deployment.
- A plan must be developed to provide prompt rescue for workers who may be suspended following a fall. A delay in rescuing a suspended worker is life threatening.
- Workers must be trained to implement the rescue plan.
- A worker using a PFAS must be monitored so it will be known if he/she should fall so the rescue plan can be implemented.
Because many work activities will be performed at a height that is less than the maximum fall distance for the PFAS, such fall protection would be considered inadequate whether operating a scissor lift or aerial lift. Yet it is commonplace to see employees on scissor lifts and the various types of aerial lifts using personal fall arrest equipment. To repeat, ANSI A92.2 states, “During operation of the aerial device all platform occupants shall use appropriate fall protection connected to the aerial device at the platform position.” The use of the word “appropriate” makes fall protection performance based. It is left to the employer to determine what might be appropriate. Nowhere is it stated that appropriate fall protection means a PFAS. And it is the opinion of this writer that a PFAS is not appropriate fall protection for workers using any type of aerial lift simply because so much of the work will be at a height which will not afford adequate fall space. Instead, fall restraint should be used to prevent falls from occurring.
After all, when applying the hierarchy of controls to fall protection, engineering controls (fall restraint) trumps personal protective equipment (personal fall arrest system).
Employers having the most effective EHS programs recognize that OSHA standards are the bare minimums and that full compliance is neither possible nor does it guarantee worker safety. For this reason, they have, in many cases, exceeded OSHA requirements. Many employers feel that requiring workers to tie off while using scissor lifts is an acceptable method to provide an additional layer of protection. The logic in this decision appears sound until you begin to dissect it. Likewise, it seems like a good idea to require the use of some type of shock absorbing device for those workers using any type of lifting work platform. But again, when you look below the surface, it makes much more sense to stop the fall rather than try to arrest it. Hopefully, the information presented here will clear some of the confusion regarding the use of elevating work platforms and fall protection.
Please feel free to contact me at firstname.lastname@example.org if you have questions about this or if we at EI can assist you with your EHS needs.