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Required by OSHA March, 1st 2020
The responsibility for training is currently upon the employer/user to train operators of AWP equipment. Section 8.5.1 of ANSI/SIA A92 Standards lists what should be included in operator general training, and Section 8.5.3 of those same standards addresses what should be included in familiarization. However, neither answers the question regarding what requirements are to be met to educate operators to a minimum standard. This document recommends the best practices for those minimum requirements.
ANSI standards and OSHA regulations are often confused because they generally address the same issues. In fact, many OSHA regulations were written based on ANSI standards. Also, OSHA often adopts ANSI standards via “incorporation by reference.” When standards are adopted or incorporated, they become part of the OSHA regulation and are no longer voluntary.
According to the ANSI/SIA A92 Standards, when a user directs or authorizes an individual to operate an aerial work platform, the user must ensure that the individual is trained before being assigned to operate it. The operator must receive general training on the type of AWP equipment being assigned. Instructions should include the inspection, application, recognition, and avoidance of hazards associated with that equipment. Additionally, the operator must receive AWP equipment model-specific familiarization on the particular model that he/she will be operating.
In 2009 22 workers nationwide suffered a fatal injury while operating an aerial lift. While this equipment can be very useful, it can also be extremely dangerous. Operators are at risk of injury from falls, struck by, caught in between, and electrocution. Aerial lifts have replaced scaffolding and ladders at many job sites. The fact is that many workers are injured or killed on aerial lifts each and every year.
General instructions for operators regarding the inspection, application, and operation of AWP equipment, including recognition and avoidance of hazards associated with their use, are covered in Section 8.5.1 of ANSI/SIA Standards A92.3, A92.5, and A92.6. (See page 17 for details of the standards.) These and other industry practices require the inclusion of, but are not necessarily limited to, the following issues and requirements:
The actual operation of the aerial platform “under the direction of a qualified person.” The need for the trainee to operate the aerial platform(s) for a sufficient period of time to demonstrate proficiency in the actual operation of all functions of the aerial platform.
That much of the general training should take place in the classroom.
Regulations and standards.
The need to perform workplace inspections.
Recognition and avoidance of common hazards.
Operator warnings and instructions.
The purpose and use of manuals.
A pre-start inspection.
Factors affecting stability.
Personal protective equipment.
General equipment components.
Safe use of equipment.
The proper selection of the AWP equipment for the job at hand.
The application and understanding of typical options that are likely associated with larger machines: e.g. outriggers/stabilizers, extendable axles, envelope management systems, load moment
devices, dual capacity
Let’s look at things that you should do before operating an aerial lift:
Only competent and properly trained personnel should operate aerial lifts.
All operators need to be trained on the model of the aerial lift that they will be using.
Obstacles should be identified and job site thoroughly inspected prior to work:
Verify whether the ground is soft, unstable, or uneven.
Know what other equipment or workers are on-site and where they are.
Where are the overhead power lines?
Look out for pedestrians and vehicles.
You must always, inspect your fall arrest equipment before use. Fall arrest equipment must include a full-body harness with an appropriately sized lanyard. A body belt with appropriate sized lanyard must only be used as part of a fall restraint system.
The size of the lanyard should not allow the worker to come in contact with a lower surface.
Be sure that you attach to the anchor point as soon as you enter the work basket.
Operating an aerial lift:
Aerial Lift Dos:
Always keep your whole body inside of the basket while maneuverings near other structures.
Identify hazards such as pinch points and getting your body trapped between the lift and solid objects.
Always use 100% of the tie off procedures while working in the basket.
Always move the basket to another position rather than overreaching the handrails.
Keep the lift clear of electrical lines. Avoid obstructions; getting caught, hooked, or snared could cause the
lift to tip over as it is moved or raised.
Verify that the surface is sound and stable and verify that the breaks are set before elevating.
Verify that the ground is stable for outriggers when applicable.
Wheels must be chocked is when on an incline.
In regards to wind speeds, always follow the manufacturer’s restrictions and recommendations.
Aerial Lift Don’ts:
Never stand on the handrails to reach the work area.
Never overload the lift. This can cause it to topple over.
Know your equipment rating because, many lifts are rated for only two people plus 50lbs of material, tools, and equipment.
Do the OSHA Construction standards apply to me?
- The standards apply to:
- All contractors who enter into contracts which are for construction, alteration, and/or repair, including painting and decorating. [29 CFR 1926.10(a)]
- All subcontractors who agree to perform any part of the labor or material requirements of a contract. [29 CFR 1926.13(c)]
- All suppliers who furnish any supplies or materials, if the work involved is performed on or near a construction site, or if the supplier fabricates the goods or materials specifically for the construction project, and the work can be said to be a construction activity. [29 CFR 1926.13(c)]
- The controlling contractor assumes all obligations under the standards, whether or not he subcontracts any of the work. [29 CFR 1926.16(b)]
- To the extent that a subcontractor agrees to perform any part of the contract, he assumes responsibility for complying with the standards with respect to that part. [29 CFR 1926.16(c)]
- With respect to subcontracted work, the controlling contractor and any subcontractors are deemed to have joint responsibility. [29 CFR 1926.16(d)]
Final Rule to Update General Industry Walking-Working Surfaces and Fall Protection Standards
Falls from heights and on the same level (a working surface) are among the leading causes of serious work-related injuries and deaths. OSHA has issued a final rule on Walking-Working Surfaces and Personal Fall Protection Systems to better protect workers in general industry from these hazards by updating and clarifying standards and adding training and inspection requirements.
The rule affects a wide range of workers, from painters to warehouse workers. It does not change construction or agricultural standards.
The rule incorporates advances in technology, industry best practices, and national consensus standards to provide effective and cost-efficient worker protection. Specifically, it updates general industry standards addressing slip, trip, and fall hazards (subpart D), and adds requirements for personal fall protection systems (subpart I).
OSHA estimates that these changes will prevent 29 fatalities and 5,842 lost-workday injuries every year.
Benefits to Employers
The rule benefits employers by providing greater flexibility in choosing a fall protection system. For example, it eliminates the existing mandate to use guardrails as a primary fall protection method and allows employers to choose from accepted fall protection systems they believe will work best in a particular situation – an approach that has been successful in the construction industry since 1994. In addition, employers will be able to use non-conventional fall protection in certain situations, such as designated areas on low-slope roofs.
As much as possible, OSHA aligned fall protection requirements for general industry with those for construction, easing compliance for employers who perform both types of activities. For example, the final rule replaces the outdated general industry scaffold standards with a requirement that employers comply with OSHA’s construction scaffold standards.
Most of the rule will become effective 60 days after publication in the Federal Register, but some provisions have delayed effective dates, including:
- Ensuring exposed workers are trained on fall hazards (6 months),
- Ensuring workers who use equipment covered by the final rule are trained (6 months),
- Inspecting and certifying permanent anchorages for rope descent systems (1 year),
- Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures (2 years),
- Ensuring existing fixed ladders over 24 feet, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system (2 years), and
- Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet (20 years).