Standard Interpretations - Table of Contents
• Standard Number: 1926.451; 1926.451(g)(1)(vii); 1926.452(w); 1926.453

July 21, 1998

Dennis Vance
Safety Specialist
Safety Services
711 Low Gap Road
Princeton, WV 24740

Dear Mr. Vance:

    RE: 1926.451(g); 1926.452(w);1926.453; 1926.502(d); CPL 2-1.23; ANSI A92.2; ANSI A92.6; scissors lift.
This is in response to your letter of May 27 to the Occupational Safety and Health Administration (OSHA) in which you asked whether an employee working from a scissors lift equipped with guardrails needed to wear a "safety harness." You further expressed concern for the confusion created by OSHA's scaffold standard and its directive, CPL 2.112 (sic). Please accept our apology for the delay in responding to this inquiry and for any previously submitted requests.

We recognize that there is confusion regarding scissors lifts and the appropriate standards governing such equipment. The confusion stems from the way OSHA's directive is worded. In CPL 2-1.23, titled "Inspection Procedures for Enforcing Subpart L, Scaffolds Used in Construction - 29 CFR 1926.450-454," dated January 7, 1997, the statement in paragraph K.9.b states that scissors lifts are addressed by 1926.453, Aerial Lifts, and not by 1926.452(w), Mobile Scaffolds. The directive should have more clearly indicated that only aerial lifts meeting the design and construction of the American National Standards Institute (ANSI) A92.2, Vehicle Mounted Elevating and Rotating Work Platforms, are addressed by 1926.453 since the coverage of that section is specifically limited to such