When working at heights, employees need to be protected from falling. On a scissor lift, a fall protection harness is not required, provided that the guardrails on the scissor lift meet the requirements of the fall protection standard.
Scissor Lift Fall Protection Letter of Interpretation
OSHA has issued a letter of interpretation on this specific issue. It concludes:
“A worker need only be protected from falling by a properly designed and maintained guardrail system. However, if the guardrail system is less than adequate, or the worker leaves the safety of the work platform, an additional fall protection device would be required.”
Guardrail Safety Requirements
If you are using the guardrails on a scissor lift as fall protection, they must meet the OSHA Subpart M requirements. Here are the highlights:
* Top rails must be 42 inches high, plus or minus three inches.
* If there is no parapet wall at least 21 inches high, midrails must be installed midway between the top edge of the guardrail system and the working level.
* Guardrail systems must be able to withstand a force of two hundred pounds applied outward at the top edge of the guardrail system.
OSHA Letter of Interpretation for Fall Protection on Scissor Lifts
29 CFR Subpart M 1926.502 – Fall Protection System Criteria and Practices
29 CFR Subpart L 1926.452 – Additional Requirements Applicable to Specific Types of Scaffolds