Fall Protection in Vehicle-Mounted Elevating and Rotating Aerial Devices

Fall Protection in Vehicle-Mounted Elevating and Rotating Aerial Devices

The time to act on fall protection is not after an incident occurs. It’s now.

What is the first thing that you think about when you see the words “fall protection?” Do you think of a harness? Guard rails? Or perhaps you think of OSHA violations and worker’s compensation cases. Whatever your first thought might be, it is my hope that your immediate next thought is about safety and proper fall protection training.

Falls from heights are a leading cause of workplace injuries and fatalities. Fall protection is routinely in the OSHA Top 10 most frequently cited standards; in 2021, Fall Protection ranked as the #1 most frequently cited standard, and Fall Protection Training ranked #6. Thus far in 2022, Fall Protection again ranks as the #1 most frequently cited standard with Fall Protection Training ranking #4 and Aerial Lifts ranking #9. Fall Protection Systems rank the #10 most cited standard. Why is something so potentially hazardous discounted by aerial lift operators year after year? Let’s dive further into fall protection and how both workers and organizations can protect themselves.

What is Fall Protection?

Fall protection is the use of controls designed to protect personnel from falling, or in the event that they do fall, to prevent severe injury. Fall protection systems, when properly utilized, are designed to prevent injury and death should a fall incident occur. Aerial unit designs are required to provide fall protection with the first line of protection being guard rails. In a vehicle-mounted elevating and rotating aerial unit, the shape and design of the platform satisfies the requirements for guard rails as the first line of fall protection.

In addition to the requirement for aerial units to provide fall protection, there exists a requirement that operators use personal fall protection to protect against ejection from the platform. Here operators have a choice: a fall arrest system or a fall restraint system.

Are fall arrest systems the same as fall restraint systems? Fall arrest systems prevent serious injury should a fall incident occur; however, they do not prevent an operator from falling out of a platform. These systems protect an operator while the fall occurs by limiting the force an operator’s body will experience and preventing the operator from hitting the ground. Fall arrest systems are not synonymous with fall restraint systems which prevent individuals from falling. Fall restraint systems must prevent a fall from occurring, and the operator must not be exposed to a fall. Although it is commonly thought that fall restraint systems have a specific lanyard length to prevent falls, these systems do not have a lanyard length maximum.

One company has patented technology on a platform liner that offers both fall protection and fall restraint on an insulated unit. In this special dual-use liner, the operator is retained in the platform; however, should the platform tear off, the operator has a secondary restraint strap tied to the boom tip. The use of this technology provides owners and users of vehicle-mounted elevating and rotating aerial devices comfort in knowing that users of the unit are protected against both ejection and falls should a catastrophic failure occur.

Fall Protection, OSHA and ANSI

One of the first hazards associated with aerial lifts that OSHA mentions is a fall from an elevated level. OSHA Standard 1926.453 covers aerial lift operation and safety, and OSHA Standard 1926.502 describes fall protection systems criteria and practices. Through these standards and letters of interpretation, owners and users of vehicle-mounted elevating and rotating aerial units can derive their fall protection requirements. OSHA points to American National Standards Institute (ANSI) to provide further guidance on fall protection and guidance on training.

ANSI Fall Protection Guidance

Aerial lift manufacturers are required to provide anchorage(s) on the boom, platform or platform mounting with the number of anchorages equaling or exceeding the number of permissible occupants. So, two operators cannot attach to the same anchorage point? Wait, they can! (With a caveat of course.) Two operators CAN attach to the same anchorage point if the anchorage is rated and identified as being for more than one person.

Are body belts authorized as part of a personal fall arrest system? While originally acceptable, as of January 1, 1998, body belts are not acceptable as part of a personal fall arrest system. Full body harnesses, connecting components and lanyards must meet the requirements of their applicable ANSI/ASSP regulation (ANSI/ASSP Z359.11, Z359.12, and Z359.3 respectively). Body belts are still allowed for body restraint systems; however, they are unacceptable for fall arrest systems. A full-body harness is a must.

While we are talking about body belts and full body harnesses, I would be remiss if we did not discuss lanyards. Personal fall arrest systems (remember, fall restraint systems—which do not have a lanyard length requirement—prevent an operator from falling out of the platform while fall arrest systems protect the operator should a fall incident occur) must limit falls to no more than six feet and must limit the arresting force on an employee to 1,800 pounds. Shock absorbing lanyards are preferred if using a fall arrest system. The proper lanyard length must be selected to meet the above requirements and limit the fall so the operator does not contact any lower level.

Fall Protection Training

The time to think about fall protection training is not after an accident; the time is now. The proper use of personal fall protection equipment is a portion of operator General Training which is required for all operators of vehicle-mounted elevating and rotating aerial devices (see: ANSI A92.2). Only personnel who have received general instructions by a qualified person regarding the inspection, application and operation of aerial devices, including the proper inspection and use of fall protection equipment, may operate an aerial device. Some manufacturers offer in-person general training and online fall protection courses to get operators started on the right training path.

Personal fall protection must be inspected prior to each use, must be in good working condition and must not have ever been involved in a fall incident. Owners of aerial units have great responsibility to ensure their users are trained; however, it is important to note that it is the individual’s responsibility to inspect his or her own personal fall protection equipment before each use. They must also read, understand and follow all instructions and cautions associated with the fall protection system, including those attached to and/or packed with all personal protective equipment. Formal fall protection training will elaborate further on the inspection and proper use of fall protection equipment.

Lanyard Detection Systems

As aerial units have become increasingly complex and advanced, manufacturers have explored how to make the units more efficient and safer. New technology now exists that can detect whether an operator has correctly fastened their lanyard to the proper anchorage. The lanyard detection system is a new technology that has been introduced to reduce fall incidents. If an operator has not correctly fastened their lanyard to the correct anchorage, the aerial unit will not operate. Telematic capabilities are available with some lanyard detection systems to provide information for owners and safety managers on which operators are consistently failing to attach their lanyard before attempting to use the aerial unit.

Be Safe!

The proper use of fall protection systems prevents serious injuries and saves lives. I implore all owners and users of vehicle-mounted elevating and rotating aerial units to inspect and use the proper fall protection systems during the use of the units. Do not wait for an OSHA fine or a fall incident to conduct fall protection training and inspections. Keep your crews safe and be committed to safety.

For more information on the use of body belts versus full body harnesses, refer to the letter of interpretation.

For more information on standards for vehicle-mounted elevating and rotating aerial devices, please refer to ANSI A92.2.

For more information on the Fall Protection Code, please refer to ANSI/ASSP Z359.1-2020.

This article originally appeared in the December 1, 2022 issue of Occupational Health & Safety.

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