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Working Safely from Elevated Heights

Each year, OSHA reveals which of its regulations are most violated by employers across the U.S., based on the number of citations given. Violations of fall protection regulations are routinely in the top 10. Given that this is a widespread issue, I’m going to use this month’s Tailgate Topic to provide a brief overview of typical fall hazards as well as some protective systems you and your company can use.

Typical Fall Hazards and Protection
Typical fall hazards in the electric utility industry include mobile and vehicle-mounted elevating work platforms (e.g., bucket trucks, aerial lifts, scissor lifts), ladders, scaffolds and pole climbing.

Fall restraint and fall arrest are both types of fall protection. Fall restraint gear includes items such as guardrails and parapet walls. It can also consist of a personal fall restraint system, which keeps you from reaching an unprotected fall point. Fall arrest gear stops you when you’re falling.

With the exception of OSHA 29 CFR 1926 Subpart V (construction), which requires fall protection on poles and towers at 4 feet (see 1926.954(b)(3)(iii)(B)), fall protection must be provided at elevations of 4 feet in general industry workplaces and 6 feet in the construction industry. If a risk assessment identifies that a specific hazard is present relative to fall protection, increasing the protection is warranted.

A guardrail system must include toe-boards, a top-rail height of 42 inches and a mid-rail height half the top-rail height. OSHA specifies a minimum toe-board height of 3.5 inches. However, if materials near the toe-board are stacked higher than 3.5 inches, you must take additional steps to prevent objects from falling, such as screening to the mid-rail or top rail of the guardrail.

At a minimum, a personal fall arrest system (PFAS) consists of a full-body harness, a lanyard or lifeline, and an anchor point that can support at least 5,000 pounds per employee. The operational practice should be as follows:

  • Ensure the PFAS fits the worker and is regularly inspected to verify that it’s still in good working condition. Full-body harness straps, when properly secured to the body, will distribute fall arrest forces over the thighs, pelvis, waist, chest and shoulders. Therefore, proper fit is crucial.
  • Attach lanyards to the dorsal D-ring only for effective fall arrest.
  • An annual inspection performed by a competent person contributes to ensuring that a PFAS is in good and functioning condition. This inspection should be documented.
  • It is essential to train personnel on proper PFAS use, maintenance and storage.

Mobile and vehicle-mounted elevating work platforms extend many feet above the ground, so falls from them can be serious and even fatal. A slight jarring movement at the base of the machine, an entanglement of aerial components or unsafe operation can cause a powerful whiplash and catapulting effect at the platform. This type of event can occur at any elevated height.

Platform operators must correctly wear and use their PFAS at all times. A properly fitted full-body harness with a lanyard or lifeline attached to the platform will reduce the potential for falls or being launched from the bucket. Safe operational practices include the following:

  • Only trained persons can operate such equipment.
  • Locate the equipment manual and become familiar with it.
  • Wear your PFAS with a lanyard attached to an anchor point when working from the platform/bucket.
  • Attach your lanyard immediately upon entering the bucket.
  • Do not attach your lanyard to an adjacent pole, structure or piece of equipment.
  • Always stand firmly on the floor of the basket.
  • Do not sit or climb on the edge of the basket; further, do not use planks, ladders or other devices for a work position.

ANSI Updates
ANSI recently revised both the mobile elevating work platforms standard and the vehicle-mounted elevating and rotating aerial devices standard, with an increased focus on training, assessments, rescue and design standards. By interpretation letter (see, OSHA has explained that they “use the ANSI requirements to help establish what the industry practice is in regard to operator qualifications.” Translation: Employers need to look to ANSI A92/A92.2 for operator training requirements that comply with OSHA’s requirement to train. A92/A92.2 defines operator training requirements and details about what training topics to cover when training someone for the first time or when training someone on a new piece of equipment.

About the Author: Charles Keeling, CUSP, is a 35-year safety professional in general industry and construction. He is also a certified New York State Workplace Safety Consultant and an ASSP area director. Keeling earned a bachelor’s degree in fire and emergency management and currently works with PSEG Long Island conducting safety and regulatory compliance duties. He can be reached at