Test Your OSHA I.Q.

Do Workers on Scaffolds with Guardrails Need to Tie-Off?

Date First Published on SafetySmart Compliance: December 26th, 2012
Topics: Fall Protection | PPE | Scaffolding |

Worker on scaffold with guardrail

Situation

Workers are working on a scissor lift platform scaffold over 10—feet-high that extends beyond the lift’s wheelbase. The platform is equipped with guardrails that meet ANSI standards and the scissor lift itself meets all of the requirements for a scissor lift under the OSHA Scaffolding for construction standards (Part 1926 Subpart L).

Question

Must the workers tie-off when they’re on the platform?

A. Yes, because they’re at risk of falling more than 10 feet.
B. Yes, because guardrail systems must be supplemented by fall arrest systems.
C. No, because a properly designed guardrail system is sufficient fall protection.
D. No, because the platform extends beyond the scissor lift’s wheelbase.

Answer

C. As long as the platform has proper guardrails, workers don’t have to tie-off.

Explanation

This scenario, which comes from a 2005 OSHA Interpretation Letter, illustrates the fall protection options to protect construction workers on scaffolds over 10-feet-high: Specifically, you can use either a properly designed and maintained guardrail system, i.e., one that meets the requirements of Sec. 1926.451(g)(4)  or a personal fall arrest system. You don’t have to use both.

Why Wrong Answers Are Wrong

A is wrong because while the OSHA Scaffolds General Requirements standard for Construction requires you to provide fall protection for workers on scaffolds above 10 feet in elevation, it doesn’t necessarily require guardrails and personal fall arrest systems at the same time.

B is wrong because fall arrest systems are required only if:

  • There are no guardrails on the platform;
  • There are guardrails on the platform but they don’t meet the design and maintenance standards for guardrails (Sec. 1926.451(g)(4)); or
  • Workers leave the safety of the work platform.

None of these things are true in this scenario.

D is wrong because the fact that the platform of a scissor lift extends beyond its wheelbase doesn’t affect the fall protection required. Of course, you can’t use a platform in such a configuration unless the scissor lift meets the requirements for such lifts under Part 1926 Subpart L. But that’s not a problem in this scenario since we stated that the lift does comply with the Part 1926 Subpart L requirements.

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