MEWP Fall Protection Tips

Winter weather can increase the chance of slips, trips and falls for many obvious reasons: slippery conditions brought on by rain, ice or snowfall can obscure trip hazards along walking paths. However, when it comes to work performed at heights, especially on mobile elevated work platforms (MEWPs), there are some less obvious reasons risk of injury from falls increases: bulkier outerwear can affect fall protection harness fit, increased exposure to rain or moisture can cause rusting on metal harness components, or slick roads and strong winds can lead to accidental tip-overs.

Fall Hazard Statistics

When it comes to protecting workers from falls, regardless of the weather, a good starting point is to understand where the most significant risk of falling resides. According to the International Powered Access Federation (IPAF), the top MEWP categories involved with fall incidents are scissor lifts (26%), self-propelled boom lifts (24%) and vehicle-mounted lifts like bucket trucks (18%).

Rental activity is the leading market segment that suffers fall incidents, but many falls also occur on construction sites and in general industry facilities. From 2012 to 2022, approximately 55% of falls reported to IPAF resulted in worker fatality. This article will discuss basic safety essentials when operating MEWPs, as well as a special focus on the unique hazards winter weather can bring to MEWP operators and how to mitigate risk.

Fall Protection Requirements

Minimum fall protection requirements for MEWP operators can vary between pieces of equipment, which local OSHA jurisdiction the worker is in or based on printed information in user instruction manuals. It is important for employers to inform themselves and their operators which minimum requirements must be met depending on where work is being performed.

Scissor Lifts

Federal OSHA does not necessarily mandate fall protection to be worn when operating a standard scissor lift. However, OSHA 1910 (general industry) and OSHA 1926 (construction) standards mandate that operators always follow equipment manufacturer instructions.

Many scissor lifts are now integrated with an engineered anchor point on the base of the platform or on the midrails of the platform, and if the instructions require the use of these anchor points when operating the equipment, employers could potentially be cited if operators fail to comply with manufacturer instructions. Furthermore, Cal/OSHA (State of California) requires operators to wear fall protection equipment whenever an engineered anchor point is installed on a scissor lift.

When an operator must wear fall protection equipment in their scissor lift, it is important to consider which equipment will be most effective in keeping the worker contained in the platform and mitigate injuries if a fall occurs.

The Hierarchy of Fall Protection Controls (see graphic) encourages employers to utilize active travel restraint. This solution requires users to connect a fixed-length travel restraint lanyard from their body harness to the scissor lift’s anchor point. The restraint lanyard should be long enough to allow the worker to freely move around the basket, but not allow them to be ejected from the platform if they lose their balance or start to fall off the lift. There are adjustable-length travel restraint lanyards available, but they require vigilance on the user’s part to repeatedly adjust their lanyard whenever they change working positions. If the lanyard is too long when the fall occurs, the user is at risk of being ejected from the lift and would have no shock absorption equipment to mitigate fall forces. Injuries incurred from pure freefall can range from severe to fatal.

Self-retracting lifelines (SRLs) put the worker in active fall arrest, per the hierarchy. While SRLs are only effective once a user falls out of the lift, the device would significantly decrease the amount of free fall and would also absorb some of the fall forces incurred. However, since the anchor point is below the level of the user’s dorsal d-ring on their harness, users would be required to use a Class 2 SRL to comply with current American National Standards Institute (ANSI) Z359 guidelines.

Fall protection equipment instructions almost always reference ANSI Z359 in their instruction manuals, and as previously mentioned, following manufacturer instructions are required by OSHA. Employers may be tempted to provide more cost-effective fall arrest solutions like 6 foot shock-absorbing lanyards, but these devices typically require a minimum of 18.5 feet of fall clearance to guarantee safe operation. If the scissor lift operator is less than the required minimum fall clearance as set forth by the manufacturer, their user runs the risk of an unsuccessful fall arrest and contact with the ground during their fall. If a fall is not fully arrested before the user contacts the ground, fall forces will not be absorbed by the equipment and will be felt by the user — causing more severe injuries and increasing the risk of fatality.

Articulating Boom Lifts

Due to the more dangerous nature of articulating boom lifts and their risks, whether self-propelled or vehicle-mounted, almost all platforms or baskets contain an engineered fall protection anchor point for workers. As opposed to scissor lifts, federal OSHA explicitly states that fall protection is always required on boom lifts. But again, employers must decide if they want to provide active travel restraint or fall arrest equipment to the worker. At the end of the day, the equipment provided that keeps the worker safe is the best equipment to use, despite what the Hierarchy suggests. Fall arrest equipment is not inherently more dangerous, but it does not prevent a fall — it simply aims to mitigate injuries incurred from a fall. Travel restraint equipment is more effective at preventing falls, in theory, but fall arrest equipment like SRLs limit freefall and contain shock absorption, trying to account for equipment misuse and mitigate injuries incurred.

However, workers subject to EM385 standards (used by the U.S. Army Corp of Engineers and enforced on many federal government properties) explicitly prohibit the use of fall arrest equipment on articulating boom lifts and require active travel restraint equipment to be used instead. In this case, it is imperative for employers to train employees on the limitations of restraint lanyards and emphasize that extreme fall forces will be felt if the worker misuses the equipment and subjects themselves to freefall.

Unique Hazards During Winter Months

While OSHA mandates will not change in the winter months, there are certain risks that present themselves in colder weather that safety managers must mitigate.

For one, users will likely wear bulkier clothing or more layers of outerwear when working in colder climates. Employers must ensure the fall protection harness provided will fit the worker, no matter their choice of apparel. An ill-fitting harness is not a safe harness. Too tight of a harness runs the risk of accidental disconnection or malfunction. If a harness malfunctions during a fall, the user could be ejected from their harness and subject to severe injury or worse.

Slippery surfaces or slick roads can present many risks to MEWP operators during the winter. While often overlooked, slips are a dominant precursor to falls. If an operator is walking around a lift platform with an icy surface, they could be subject to slipping and falling. Even a minor slip fully contained in the basket could lead to wrist or head injuries or could cause a worker to lose their balance enough to be ejected from their lift.

Additionally, icy roads can increase the chances of lifts losing traction while moving and could cause user ejection or the unit tipping over. Also, icy conditions raise the risk of vehicle accidents, which can be extremely dangerous for vehicle-mounted lifts performing roadside repairs. Even with the best planning, falls can happen unexpectedly, and safety managers should provide equipment that will protect workers from the worst-case scenario. While it may be inconvenient for the crews assembled and put repair or maintenance projects behind schedule, workers must advocate for “stop work” authorizations if weather conditions prevent safe work from occurring.

Conclusion

The IPAF Global Safety Report of 2023 noted an increase in reports of falls occurring but also observed a decline in fatality rates among accidents. The data from the report suggests that employer actions being taken to better enforce fall protection policies and train workers on how to prevent falls while operating MEWPs are having a positive effect. While any injury incurred during work is tragic and can be a life-altering event for the worker, progress must be celebrated. A decline in fall fatality rates this year will hopefully lead to a decline in falls occurring in the near future. If we want to decrease the number of fatalities caused by falls, we must work to prevent falls from occurring in the first place. If we can prevent the falls, we can prevent tragedies.