Standard Interpretations - Table of Contents
• Standard Number: 1926.451(g); 1926.453(b)(2)(v); 1926.502(d)

February 18, 1999

Mr. Steven D. Claypool
15516 Budge St.
San Leandro, CA 94579

RE: 1926.451(g), 1926.453, 1926.502(d);

Dear Mr. Claypool:

This is in response to your letter dated July 31, 1998 to the Occupational Safety and Health Administration (OSHA), in which you express concern over the use of personal fall arrest systems to protect employees when working from aerial lifts. Your specific concern is that aerial lifts may tip over from the arresting forces generated when a worker falls while wearing a personal fall arrest system.

A provision in OSHA's aerial lift standard for construction, §1926.453(b)(2)(v), requires fall protection for employees in aerial lifts. An employer can comply with that requirement by using either a restraint system or a personal fall arrest system. A restraint system consists of a body belt or harness, lanyard and anchor. The system is arranged so that the worker is prevented from falling any distance.

A system that exposes a worker to a fall, but stops the fall within specified parameters, is a personal fall arrest system. The criteria for fall arrest systems are in 29 C.F.R. §1926, subpart M. Section 1926.502(d)(15) provides that "anchorages used for attachment of personal fall arrest equipment shall be . . . capable of supporting at least 5,000 pounds per employee attached, or shall be designed, installed and used as follows: (i) as part of a complete personal fall arrest system which maintains a safety factor of at least two . . . ."

When using a personal fall arrest system, that system must not be anchored to an aerial lift unless the aerial lift is capable of withstanding the loads imposed by an arrested fall. Under §1926.502(d)(16)(iii), the maximum