OSHA Bans Body Belts & Lanyards in Buckets

In its announcement of a Walking-Working Surfaces and Personal Protective Equipment (Subpart D) final rule on November 18, OSHA put tree care employers on notice that conventional body belts and lanyards used for fall protection in aerial lifts would no longer be acceptable as of the effective date of the rule, January 17, 2017.

The final rule also requires that employers ensure workers who use personal fall protection are trained, and retrained as necessary, about fall and equipment hazards, including fall protection systems.  Employers must provide information and training to each worker in a manner the worker understands. The deadline to have provided this training is May 17, 2017.

The traditional body belt-lanyard combination is referred to as a positioning system, and all other current OSHA standards restrict the use of positioning systems to work performed on “vertical work surfaces.” Aerial lifts are deemed to be horizontal work surfaces.

In our comments to OSHA in 2010, Tree Care Industry Association (TCIA) expressed concern that workers in tree care would not be allowed to use “positioning systems” as these systems were defined in the proposed rule. TCIA was commenting on the proposed revision to §1910.67(c)(2)(v) that presently permits workers to use positioning systems (body belts and lanyards) or personal fall arrest systems when working in aerial lifts.

In our comments, TCIA said, “… arborists often work in aerial lifts that are elevated to work positions directly above high voltage wires, trees, buildings and other structures to trim trees.” We argued there was a unique and unavoidable job hazard intrinsic in this typical work position, and that OSHA should allow the use of a body belt and two- to three-foot lanyard. This PPE combination, we reasoned, provided for the shortest overall fall distance, and thus provided the greatest protection against fatally dropping into nearby electric wires or any other potentially injurious object at a lower level. The short lanyard would minimize free fall, thereby reducing the arresting force in the system. Finally, the attachment at the operator’s waist allows for the possibility of self-rescue.

OSHA did not find our arguments on arresting force or self-rescue persuasive and actually devised a solution to the hazard of contacting a lower level we did not contemplate in 2010: the travel restraint (or work restraint) system. This is a system that prevents any fall whatsoever out of the bucket.

OSHA is revising the requirement in § 1910.67(c)(2)(v) to allow workers to use either travel restraint or personal fall arrest systems, but not positioning systems.

What this means for you is that if you are still providing body belts and lanyards for your aerial lift/compact lift operators, you will have to switch to an OSHA-compliant system by January 17. The most readily available system is a full body harness/fall arrest lanyard combination, available from many vendors including most arborist supply houses. Buckingham Manufacturing sells the BuckitTM Restraint System as a work restraint system for aerial lift applications.

If you operate in a State with a State Plan OSHA, your State is given six months to adopt regulations that are at least as stringent as the federal OSHA rule.

Please contact the TCIA office with any questions about compliance.