A description of the proposed changes are as follows:

1. TITLE 8:

GENERAL INDUSTRY SAFETY ORDERS
Chapter 4, Subchapter 7, Article 24, Section 3646(e)

Working From or On Top of an Elevating Work Platform Guardrail

INITIAL STATEMENT OF REASONS


INFORMATIVE DIGEST OF PROPOSED ACTION/PLAIN ENGLISH OVERVIEW

General Industry Safety Orders (GISO), Article 24 contains regulations pertaining to elevating work platforms and aerial devices. Elevating work platforms are devices designed to elevate work platforms in a substantially vertical direction without offsets.

An example of an elevating work platform is what is sometimes referred to as a "scissor lift." An aerial device is defined as any vehicle-mounted or self-propelled device, telescoping extensible or articulating, or both, which is primarily designed to position personnel. An example of an aerial device is what is commonly referred to as a "cherry picker."

GISO Section 3646 specifies operating instructions for elevating work platforms, including platform travel, assembly, disassembly, repair, precautions for inclement weather, and protection of personnel on the platform and on the ground when the platform is in use. Section 3646(e), prohibits the use of ladders or other objects on elevating work platforms to gain greater reach or working height. However, this section is silent about climbing, standing or sitting on the platform guardrails and the placement of planks on guardrails to extend working height.

Elevating work platforms support workers in a stable manner when used as designed. Extension of the work height of the device beyond design limits can adversely affect platform stability, thus endangering the worker and others nearby should the platform topple.

It is proposed to revise Section 3646(e) to prohibit sitting, standing or climbing on the guardrails, and also to prohibit the use of planks, ladders or other devices to gain greater work height or reach.

These proposed revisions will require employers to prohibit employees from sitting or climbing on guardrails or using the guardrails as scaffold ledges to gain greater work height.

DOCUMENTS INCORPORATED BY REFERENCE

None.

Attachments