It’s a scenario that plays out hundreds of times every day across the United States, you need to access an upper elevation using a Mobile Elevated Work Platform but you do not know if it is legal or what the correct steps to ensure that you are legal are. The practice of exiting the platform at height does happen on jobsites because it’s sometimes the safest way to carry out temporary work at height. Other times it occurs unsafely, with no instructions or guidance to follow. To start, the following are some guidelines to help ensure the safe transfer of your employees from the MEWP platform to the structure;
- Make sure he/she is preauthorized from the equipment manufacturer to do so. With Genie equipment, this comes in the form of an Exiting Elevated Boom Platform letter.
- With JLG no preauthorization is required but they do give guidelines in the form of a letter for transferring to a structure from a MEWP based on advice from OSHA.
- The operator must be trained and qualified on how to safely operate the equipment and be familiar with that specific model. In addition to complying with all local, state, provincial or federal standards, the worker must operate the boom in accordance with the restrictions outlined in the operator’s manual.
- An approved full body harness and appropriate lanyard must be worn at all times while working inside or exiting the platform. If a self-retracting lifeline/lanyard is used, it cannot allow more than 6 ft of free fall.
- Workers MUST enter or exit the platform only through the sliding mid-rail entry or gate provided and should never climb over the platform guardrails.
- When positioning the machine for entry/exit, the platform should be situated within one foot of the working surface.
- Workers should not enter/exit the elevated platform in winds exceeding 20 mph (or manufacturers recommendations).
- The MEWP shall be within 3 degrees of level or manufacturers recommendations followed if more stringent.
- The operator must ensure 100% tie-off using two lanyards when entering/exiting the platform.
- One lanyard must be attached to the platform with the second lanyard attached to the structure.
- The lanyard connected to the platform must not be disconnected until such time as the transfer to the structure is safe and complete.
- It is important to note that once you exit the lift at height, then you’re covered under fall protection standards – Subpart M, Subpart R, and Subpart L – and you must meet those requirements. Fall protection is the bottom line. Employers have to protect workers at all times.
- While some manufacturers allow the MEWP to be used as a fall arrest anchor while working from the structure, it is never allowable to belt-off to adjacent structures or poles while in the bucket.
- Some manufacturers allow operators to exit the platform to perform work on structures, if the pitch is no greater than 4:12 (18°), while using the boom platform as a tie-off anchor.
- Before you start allowing operators or employees to start climbing out of MEWP platforms you need to ensure that a thorough and specific risk assessment has been carried out for the task. The risk assessment must demonstrate that the MEWP is the safest option to gain access to the intended working location and all other means of access have been explored and rejected.
While Federal OSHA does not have a prohibition for exiting a MEWP onto a structure, the fact is that it happens daily across the United States in the construction world. In Michigan they actually have a provision for exiting a platform. It says, under rule R 408.43214 Fall protection Rule 3214, “Employees may exit the platform with the knowledge and consent of the employer.”
At the end of the day, if all the procedures and best practices are followed, this author would feel much safer transferring from a MEWP to a structure when compared to a ladder. In March of 2020 the new ANSI A92 standard will go into affect, if you would like to learn more about how this will affect your company read this great blog by Scott Seppers.
Author: Bryan McClure