OSHA rescinds fall protection interpretation

October 5, 2011

Washington – OSHA has rescinded a 2009 letter of interpretation regarding a specific shock-absorbing lanyard and OSHA fall protection system requirements.

The agency originally said use of an unnamed manufacturer’s lanyard would not be in compliance with aerial lift requirements because the lanyard needs an anchor point of at least 18.5 feet. (If the lift is less than that minimum height, it would not protect the worker.)

This interpretation prompted questions regarding the use of body harnesses married with appropriate lanyards for fall protection in aerial lifts. To avoid confusion, OSHA rescinded the letter, and stressed in a memorandum that citations would be issued only when evidence shows that a fall arrest system allowed a free fall of more than 6 feet or permitted contact with a lower level – and not base this conclusion on manufacturer-provided information.

The agency outlined three ways in which an employer may comply with fall protection requirements when using an aerial lift:

  • Use of a body belt with a tether anchored to the boom or basket
  • Use of a body harness with a tether
  • Use of a body harness with a lanyard