Fall-Protection Systems for Mobile Elevated Work Platforms -
932-1-IPG-065
Effective Date: April 18, 2006
1. Subject
Fall Protection Systems for Mobile Elevated Work Platforms
2. Definitions
"Aerial platform"
Means a work platform attached to an extendible or articulating support that is designed to position personnel and their tools and materials, at elevated work locations.
"Vehicle-mounted aerial platform" (bucket truck)
Means an aerial platform connected to an extendible or articulating support that is mounted on a vehicle. The elevating functions of the aerial platform are typically controlled from the platform, often with a secondary "overriding" set of controls in the vehicle, whereas the mobile functions of the vehicle are typically controlled only from the vehicle.
"Self-propelled elevated work platform" (scissor lift)
Means equipment with an integrated mobile power source and extendible supports connected to an aerial platform, which can be elevated vertically but cannot be positioned completely beyond the base of the equipment. The mobile and elevating functions of the equipment are typically controlled from the aerial platform.
"Boom-type elevating work platform" (boom lift)
Means equipment with an integrated mobile power source and extendible support connected to an aerial platform which can be positioned completely beyond the base of the equipment. The mobile and elevating functions of the equipment are typically controlled from the aerial platform.
"Materials handling equipment" (MHE)
(As per Canada Occupational Health and Safety Regulations , Part XIV, section 14.1), means equipment, including its supporting structures, auxiliary equipment and rigging devices, used to transport, lift, move or position persons, materials, goods or things and includes mobile equipment used to lift, hoist or position persons, but does not include an elevating device that is permanently installed in a building.
3. Issue
The Canada Occupational Health and Safety Regulations (COHSR), paragraph 12.10(1)(a), require the employer to provide a fall-protection system to any person working from an unguarded structure or on a vehicle, at a height of more than 2.4 metres above the nearest permanent safe level or above any moving parts of machinery or any other surface or thing that could cause injury to a person on contact where it is not reasonably practicable to eliminate or control the risk of falling (reference COHSR section 12.1). Exceptions include where employees are installing or removing a fall-protection system in accordance with written instructions as per COHSR subsection 12.10(5), or where it is deemed not reasonably practicable to comply and the provisions of COHSR subsections 12.10(1.1) and (1.2) are followed.
In response to a Court decision, COHSR subsection 12.10(1) was revised in October 2002, to explicitly include vehicles in its application. Subsequently the Interpretations, Policies and Guidelines (IPG) document entitled "Fall-Protection Systems for Vehicles", 932-1-IPG-064 (IPG-064), was published. It provides clarification of the revised regulation and describes the criteria to consider when assessing an employer's position that it is not reasonably practicable to provide fall protection to employees who are required to work (climb) on vehicles or their loads where there is a hazard of falling. IPG-064 reinforces the principles of preventive measures, namely, elimination of the hazard of falling, reduction of the hazard and finally, provision of fall-protection systems.
The types of vehicles envisioned in IPG-064 include auto haulers, bulk carriers, and flatbed trailers. These vehicles, and the reasons for a person to be working on them at heights, are significantly different from situations involving bucket trucks, scissor lifts and boom lifts. IPG-064 addresses situations where a person accesses vehicles to secure or check on loads, or perform maintenance on the vehicle, which is performed while the vehicle is stationary. In this regard the stationary vehicle is very similar to a structure, and IPG-064 considers guardrails sufficient to protect against the hazard of falling for persons working on stationary vehicles. However, bucket trucks, scissor lifts and boom lifts are intended to be moved and operated while occupied by a person at elevated heights. Under these conditions the hazard of falling is greater due to the movement of the equipment.
Therefore, notwithstanding IPG-064, it is necessary to clarify how COHSR paragraph 12.10(1)(a) applies to a person working from a vehicle-mounted aerial platform (bucket truck), a self-propelled elevated work platform (scissor lift), or a boom-type elevating work platform (boom lift).
4. Question
Is there a requirement for an employer to provide a person with a personal fall-protection system, where the person is working from a guarded aerial platform as part of a bucket truck, scissor lift or boom lift, that is elevated more than 2.4 metres above the nearest permanent safe level or above any moving parts of machinery or other surface or thing that could cause injury to the person on contact?
5. Program Position
For the provisions of COHSR paragraph 12.10(1)(a) to apply, it must be established that bucket trucks, boom lifts, and scissor lifts are vehicles. This is accomplished by first establishing that these types of equipment are motorized "materials handling equipment" (MHE), and then that motorized MHE are vehicles.
The definition of MHE is provided in section 14.1 of COHSR and, "…includes mobile equipment used to lift, hoist or position persons…" This includes bucket trucks, boom lifts and scissor lifts.
COHSR section 12.13 was discussed in appeals officers' (AO) decisions 01-025, 04-018 and Federal Court decision 2003-FCT 391, which all relate to a direction issued requiring employees to wear high-visibility vests or other similar clothing when working around moving forklifts. In AO decision 01-025, the employer argued that a forklift (i.e. type of motorized MHE) was not a vehicle; however, the appeals officer ruled that it was. In the Federal Court decision 2003-FCT 391, the Court found that:
[13] "In concluding that subsection 12.13(a) applies, the appeals officer first determined that a forklift is a moving vehicle within the contemplation of section 12.13 of the Regulations. No challenge is made to that finding."
Bucket trucks, scissor lifts, and boom lifts are vehicles that are intended to be moved and operated while occupied by a person, at an elevated height. These vehicles are operated both "horizontally" by driving, and "vertically" by elevating the aerial platform. The hazard of a person falling from the elevated aerial platform stems in large part from this horizontal and/or vertical movement of the equipment during its operation. These movements can make it difficult to keep the aerial platform level and can cause it to bounce and sway. These effects are much greater for an aerial platform that extends beyond the base of the equipment, i.e., bucket trucks and boom lifts. In these cases, guardrails are not enough to reduce the hazard of falling to within safe limits while the equipment is in operation. Therefore, a personal fall-protection system is required for a person working at a height greater than 2.4 metres on an aerial platform of a bucket truck or boom lift, even if the platform is guarded.
On the other hand, the design of the scissor lift, such that the aerial platform cannot be positioned completely beyond its base, makes it significantly more stable than a bucket truck or boom lift when vertically raising and lowering the aerial platform. For this reason, an additional personal fall-protection system is not required for a person working on a scissor lift at a height greater than 2.4 metres if the aerial platform is guarded and the only vehicle operation while stationary is the vertical raising and lowering of the aerial platform
In conclusion, bucket trucks, boom lifts and scissor lifts are all considered to be vehicles. Personal fall protection is required for persons working above 2.4 metres in bucket trucks and boom lifts, regardless of whether the aerial platform is guarded. Scissor lifts however, are exempted from this requirement if they are not being operated as a vehicle, i.e., are not being moved horizontally. Failure to comply with this requirement constitutes a violation of paragraph 125.(1)(l) of the Canada Labour Code , Part II (Code), and COHSR paragraph 12.10 (1)(a).
Reference Notes
The following standards were researched and considered during the development of this IPG:
Bucket Trucks
Canadian Standards Association, CSA C225-00 - Vehicle-Mounted Aerial Devices
10.2 "During operation of the aerial device, all platform occupants shall use fall protection appropriate to the aerial device at the platform position."
British Columbia: Worksafe BC-Workers Compensation Act, OHS Regulations - Part 13 Ladders, Scaffolds and Temporary Work Platforms
13.33(1) "A worker on a boom-supported elevating work platform must wear a personal fall arrest system secured to an anchor meeting the requirements of Part II (Fall Protection)."
Saskatchewan: Occupational Health and Safety Regulations, 1996, Chapter 0-1.1 Reg. 1, Part XII, Scaffolds, Aerial Devices, Elevating Work Platforms and Temporary Supporting Structures
192(2)(h) "An employer or contractor shall not require or permit a worker to be raised or lowered by any aerial device or elevated work platform or to work from a device or platform held in an elevated position unless the worker is provided with and is required to use fall-arrest protection pursuant to section 116."
Ontario: Occupational Health and Safety Act, Ontario Regulation 213/91 Construction Projects - Elevating Work Platform
148(e) "An elevating work platform shall not be moved unless all workers on it are protected against falling by a safety belt attached to the platform." (O. Reg. 213/91, s. 148.)
New Brunswick: Occupational Health and Safety Act (O.C. 91-1035), Regulation 91-191, Part XV, Materials Handling Equipment and Personnel Carrying Equipment
232(2) "Where an employee is required to work from the bucket of an aerial device that is more than 3m above a safe working level, the employee shall use an individual fall-arresting system that is securely anchored to the upper boom of the aerial device."
Nova Scotia: Fall Protection and Scaffolding RegulationsN.S. Reg. 2/96), Part III: Scaffolds and Work Platforms
36(11)(e) "A power operated elevating work platform shall not be moved vertically or horizontally unless all persons on it are protected against falling by a fall arrest system attached to an anchor point on the work platform."
36(12) "Where a person is working on an elevated work platform, a fall arrest system, attached to an anchor point, shall be worn at all times."
Newfoundland: Occupational Health and Safety Regulations 1165/96, Vehicle Mounted Work Platforms (104/79 s38)
101.(9) "Occupants of aerial baskets shall wear safety-belts secured to the boom."
United States of America, (OSHA): Part 1910, Occupational Safety and Health Standards; Subpart F, Powered Platforms, Manlifts, and Vehicle-mounted Work Platforms; Standard 1910.67, Vehicle-mounted Elevating and Rotating Work Platforms
1910.67(c)(2)(v) "A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift."
Scissor Lifts
Canadian Standards Association, CSA B354.2 01 Self-Propelled Elevating Work Platforms
6.4.1 "The guardrail system of the aerial platform provides fall protection, but worksite rules or requirements of the authority having jurisdiction may require additional fall protection equipment to be used. In such cases the equipment shall be worn and attached to the anchorage(s) in accordance with the manufacturer's instructions."
Saskatchewan: Occupational Health and Safety Regulations, 1996, Chapter 0-1.1 Reg. 1, Part XII, Scaffolds, Aerial Devices, Elevating Work Platforms and Temporary Supporting Structures
192(2)(h) "An employer or contractor shall not require or permit a worker to be raised or lowered by any aerial device or elevated work platform or to work from a device or platform held in an elevated position unless the worker is provided with and is required to use fall-arrest protection pursuant to section 116."
Ontario: Occupational Health and Safety Act, Ontario Regulation 213/91 Construction Projects - Elevating Work Platform
148(e) "An elevating work platform shall not be moved unless all workers on it are protected against falling by a safety belt attached to the platform." (O. Reg. 213/91, s. 148.)
Nova Scotia: Fall Protection and Scaffolding Regulations (N.S. Reg. 2/96), Part III: Scaffolds and Work Platforms
36(11)(e) "A power operated elevating work platform shall not be moved vertically or horizontally unless all persons on it are protected against falling by a fall arrest system attached to an anchor point on the work platform."
36(12) "Where a person is working on an elevated work platform, a fall arrest system, attached to an anchor point, shall be worn at all times."
United States of America, (OSHA): Part 1926, Safety and Health Regulations for Construction; Subpart L - Scaffolds, Standard 1926.451, Fall Protection
1926.451(g)(1)(vii) "For all scaffolds not otherwise specified in paragraphs (g)(1)(i) through (g)(1)(vi) of this section, each employee shall be protected by the use of personal fall arrest systems or guardrail systems meeting the requirements of paragraph (g)(4) of this section."
Boom Lifts
Canadian Standards Association, CSA B354.4-02 - Self-Propelled Boom-Supported Elevating Work Platforms
6.4.1.2. "All occupants of the aerial platform shall wear a fall arrest system. The fall arrest system shall allow workers to move around the platform but provide a minimum of lanyard slack. The fall arrest system shall be connected to the anchorage as provided on the aerial platform in accordance with the manufacturer's instructions. The fall arrest system shall include a full body harness and a lanyard arranged so that in the event of a fall, the forces are applied to the worker shall not exceed 6-N (1350 lbf)."
British Columbia: Worksafe BC -Workers Compensation Act, OHS Regulations - Part 13 Ladders, Scaffolds and Temporary Work Platforms
13.33(1) "A worker on a boom-supported elevating work platform must wear a personal fall arrest system secured to an anchor meeting the requirements of Part II (Fall Protection)."
Saskatchewan: Occupational Health and Safety Regulations, 1996, Chapter 0-1.1 Reg. 1, Part XII, Scaffolds, Aerial Devices, Elevating Work Platforms and Temporary Supporting Structures
192(2)(h) "An employer or contractor shall not require or permit a worker to be raised or lowered by any aerial device or elevated work platform or to work from a device or platform held in an elevated position unless the worker is provided with and is required to use fall-arrest protection pursuant to section 116."
Ontario: Occupational Health and Safety Act, Ontario Regulation 213/91 Construction Projects - Elevating Work Platform
148(e) "An elevating work platform shall not be moved unless all workers on it are protected against falling by a safety belt attached to the platform." (O. Reg. 213/91, s. 148.)
Nova Scotia: Fall Protection and Scaffolding Regulations (N.S. Reg. 2/96), Part III: Scaffolds and Work Platforms
36(11)(e) "A power operated elevating work platform shall not be moved vertically or horizontally unless all persons on it are protected against falling by a fall arrest system attached to an anchor point on the work platform."
36(12) "Where a person is working on an elevated work platform, a fall arrest system, attached to an anchor point, shall be worn at all times."
Newfoundland: Occupational Health and Safety Regulations 1165/96, Vehicle Mounted Work Platforms (104/79 s38)
101.(9) "Occupants of aerial baskets shall wear safety-belts secured to the boom."
United States of America, (OSHA): Part 1926, Safety and Health Regulations for Construction; Subpart L - Scaffolds, Standard 1926.453, Aerial Lifts
1926.453(b)(2)(v) "A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift."
"Note to paragraph (b)(2)(v): As of January 1, 1998, subpart M of this part (1926.502(d)) provides that body belts are not acceptable as part of a personal fall arrest system. The use of a body belt in a tethering system or in a restraint system is acceptable and is regulated under 1926.502(e)."
Brenda Baxter
Director General
Workplace Directorate
Employment and Social Development Canada – Labour Program
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