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OSHA 1910.67

Aerial device definitions

Subpart F

23 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.67(a)(1), what is an "Aerial device" and which equipments are included?

An aerial device is any vehicle-mounted device, telescoping or articulating, or both, used to position personnel. This definition is found in 1910.67(a)(1).

  • Included equipment: extensible boom platforms, aerial ladders, articulating boom platforms, vertical towers, and combinations of these as described elsewhere in 1910.67.

Under 1910.67(a)(2), how does OSHA define an "Aerial ladder"?

An aerial ladder is an aerial device made up of a single- or multiple-section extensible ladder. This is the definition in 1910.67(a)(2).

  • Practical note: Aerial ladders differ from boom platforms in that they are ladder-style extensible sections rather than telescoping booms.

Under 1910.67(a)(3) and (a)(4), what's the difference between an articulating boom platform and an extensible boom platform?

An articulating boom platform has two or more hinged boom sections, while an extensible boom platform has a telescopic or extensible boom (not a ladder). See 1910.67(a)(3) and 1910.67(a)(4).

  • Practical effect: Articulating booms provide multiple bending joints for maneuvering; extensible booms slide out in sections to reach height.

Under 1910.67(a)(5), what is an "Insulated aerial device" and when must its insulating value be preserved?

An insulated aerial device is one designed for work on energized lines and apparatus, and its insulating portion must not be altered in any manner that might reduce insulating value. See 1910.67(a)(5) and 1910.67(c)(2)(xi).

  • Practical tip: Do not paint, drill, or otherwise modify the insulated parts without manufacturer approval and proper testing per 1910.67(c)(3).

Under 1910.67(b)(1), when must aerial lifts conform to ANSI A92.2—1969?

Aerial devices acquired on or after July 1, 1975, must be designed and constructed to conform with ANSI A92.2—1969 unless otherwise provided in the section. See 1910.67(b)(1).

  • Equipment acquired before July 1, 1975, that did not meet ANSI A92.2—1969 may not be used after July 1, 1976 unless modified to conform to that standard and this section.

Under 1910.67(b)(2), can an aerial lift be field modified and what documentation is required?

Yes — an aerial lift may be field modified for uses other than those intended by the manufacturer, but the modification must be certified in writing by the manufacturer or an equivalent entity (for example, a nationally recognized testing laboratory) to conform with ANSI A92.2—1969 and this section. See 1910.67(b)(2).

  • Keep the written certification on file and available for inspection to demonstrate the modification preserves or improves safety.

Under 1910.67(b)(3), does 1910.67 apply to firefighting equipment or the vehicles they are mounted on?

No — the specific design and construction requirements of 1910.67 do not apply to firefighting equipment or the vehicles on which aerial devices are mounted, except the vehicle must still be a stable support for the aerial device. See 1910.67(b)(3).

  • Operational and safety checks still apply; the stability requirement remains.

Under 1910.67(c)(2)(i), what daily pre-use checks are required for extensible and articulating boom platforms?

The lift controls must be tested each day prior to use to ensure they are in safe working condition. This requirement is in 1910.67(c)(2)(i).

  • Practical checks: test all upper and lower controls, emergency stops, interlocks, and verify labels and markings are legible.

Under 1910.67(c)(2)(ii), who is allowed to operate an aerial lift?

Only trained persons may operate an aerial lift. See 1910.67(c)(2)(ii).

  • Training should cover manufacturer instructions, safe operation, hazards (including electrical), and emergency procedures; maintain records as appropriate.

Under 1910.67(c)(2)(iii), is "belting off" to an adjacent pole or structure allowed while working from an aerial lift?

No — belting off to an adjacent pole, structure, or equipment while working from an aerial lift is not permitted. See 1910.67(c)(2)(iii).

  • Instead, use an appropriate personal fall arrest or travel restraint system attached to the boom or basket per 1910.67(c)(2)(v).

Under 1910.67(c)(2)(iv), how must employees position themselves inside the basket when working from an aerial lift?

Employees must always stand firmly on the floor of the basket and may not sit or climb on the edge of the basket or use planks, ladders, or other devices to gain a work position. See 1910.67(c)(2)(iv).

  • Never extend your reach by climbing on the basket; reposition the lift or use approved extensions designed by the manufacturer.

Under 1910.67(c)(2)(v), when must a personal fall arrest or travel restraint system be used on an aerial lift?

A personal fall arrest or travel restraint system that meets the requirements in subpart I must be worn and attached to the boom or basket when working from an aerial lift. See 1910.67(c)(2)(v).

  • Practical note: Use anchorage points approved by the manufacturer and equipment meeting the applicable subpart I requirements referenced in the standard.

Under 1910.67(c)(2)(vi), what must employers do about boom and basket load limits?

Employers must not exceed boom and basket load limits specified by the manufacturer. See 1910.67(c)(2)(vi).

  • Include tools, materials, and workers when calculating load; post load limits visibly and train workers to respect them.

Under 1910.67(c)(2)(vii) and (c)(2)(viii), what vehicle setup and travel restrictions apply to aerial lifts?

Before using an aerial lift, set the brakes and position outriggers on pads or a solid surface, and do not move an aerial lift truck with the boom elevated and personnel in the basket unless the equipment is specifically designed for that operation. See 1910.67(c)(2)(vii) and 1910.67(c)(2)(viii).

Under 1910.67(c)(2)(ix), what control features must articulating and extensible boom platforms have?

They must have both platform (upper) and lower controls; upper controls should be in or beside the platform and within easy reach, and lower controls must be able to override the upper controls. See 1910.67(c)(2)(ix).

  • Controls must be plainly marked for their function, and lower level controls may not be operated without permission from the employee in the lift except in an emergency.

Under 1910.67(c)(2)(x), are climbers (climbing spikes) allowed while working from an aerial lift?

No — climbers shall not be worn while performing work from an aerial lift. See 1910.67(c)(2)(x).

  • Use approved fall protection attached to the lift instead of climbing gear that could create a fall hazard or damage insulating equipment.

Under 1910.67(c)(2)(xi) and 1910.67(c)(3), what electrical testing and maintenance apply to insulated aerial lifts?

The insulated portion of an aerial lift must not be altered in any manner that might reduce its insulating value, and electrical tests must be made in conformance with ANSI A92.2—1969 Section 5 (with approved equivalent DC tests allowed by the manufacturer). See 1910.67(c)(2)(xi) and 1910.67(c)(3).

  • If using DC tests, they must be approved by the equipment manufacturer or equivalent entity per 1910.67(c)(3) text.

Under 1910.67(c)(4), what bursting safety factor is required for aerial lift hydraulic and pneumatic components?

All critical hydraulic and pneumatic components must comply with the bursting safety factor provisions in ANSI A92.2—1969 Section 4.9, and all noncritical components must have a bursting safety factor of at least two to one. See 1910.67(c)(4).

  • Critical components are those whose failure would cause free fall or free rotation of the boom.

Under 1910.67(c)(5), what welding standards must be followed when welding aerial device components?

All welding must conform to the American Welding Society (AWS) standards incorporated by reference in 1910.6, specifically AWS B3.0—41, AWS D8.4-61, AWS D10.9-69, and AWS D2.0-69 as listed in 1910.67(c)(5)(i)-(iv).

  • Use qualified welders and procedures in accordance with these AWS documents to meet the standard's requirements.

Regarding 1910.67(c)(2)(vii) and wheel chocks, when must wheel chocks be used on aerial lifts?

Wheel chocks must be installed before using an aerial lift on an incline. This requirement is stated in 1910.67(c) text and reinforced under the specific platform provisions.

  • Also set brakes and position outriggers on pads or solid surfaces per 1910.67(c)(2)(vii).

Under 1910.67(c)(2)(ix), may lower-level controls be used without the basket worker's permission?

No — lower level controls shall not be operated unless permission has been obtained from the employee in the lift, except in case of emergency. See 1910.67(c)(2)(ix).

  • In emergencies, lower controls may override upper controls to protect the employee's safety.

Under 1910.67(c)(2)(viii) and related paragraphs, what inspections are required before moving an aerial lift for travel?

Before moving an aerial lift for travel, inspect the boom(s) to ensure they are properly cradled and outriggers are in stowed position, except where the equipment is designed to travel with the boom elevated under the conditions in 1910.67(c)(2)(viii). See also 1910.67(c)(2)(xii).

  • Verify cradles, locking devices, and other restraining systems are engaged before travel.

How does 1910.67 address work near overhead electric lines and which other OSHA rule should be consulted?

For operations near overhead electric lines, 1910.67 refers employers to the electrical safe work practices in 1910.333(c)(3), so those requirements must be followed in addition to the aerial lift rules. See 1910.67(b)(4).

  • Coordinate with qualified electrical workers and maintain required clearances per 1910.333(c)(3).