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OSHA 1926SubpartLAppC

National Consensus Standards List

Subpart L

17 Questions & Answers

Questions & Answers

Under 1926 Subpart L App C, is Appendix C mandatory or optional for employers to follow?

Appendix C to Subpart L of Part 1926 is non-mandatory guidance and does not create new legal obligations for employers. See 1926 Subpart L App C which is labeled as a “(Non-mandatory) Appendix.” Employers must still comply with the mandatory scaffold rules in Subpart L itself even if they choose not to adopt the consensus standards listed in Appendix C.

Under 1926 Subpart L App C, does following a listed national consensus standard (like ANSI/SIA A92.2-1990) guarantee OSHA compliance?

Following a listed national consensus standard can help demonstrate compliance but does not automatically guarantee OSHA compliance with the mandatory regulations. Appendix C lists voluntary consensus standards such as ANSI/SIA A92.2-1990, and you can consult them for guidance; however, employers remain responsible for meeting the mandatory requirements in Subpart L. For more detail see 1926 Subpart L App C.

Under 1926 Subpart L App C, which ANSI/SIA A92 standards are listed as relevant to scaffolds and aerial devices?

Appendix C lists several ANSI/SIA A92 series standards relevant to aerial devices and related equipment, including A92.2-1990, A92.3-1990, A92.5-1990, A92.6-1990, A92.7-1990, A92.8-1993, and A92.9-1993. You can view the listing in 1926 Subpart L App C for the exact titles and years.

Under 1926 Subpart L App C, if my equipment was built to a newer ANSI A92 standard than those listed, should I follow the newer standard or the versions in Appendix C?

You should follow the most current safe practice that applies to your equipment, but you must still meet the mandatory OSHA requirements in Subpart L; the versions in Appendix C are non-mandatory references. Appendix C lists specific older editions (for example, ANSI/SIA A92.6-1990), but using a newer ANSI standard is generally acceptable as improved guidance. Refer to 1926 Subpart L App C and ensure any newer practices also comply with mandatory Subpart L rules.

Under 1926 Subpart L App C, can an employer rely on a consensus standard listed in Appendix C instead of following manufacturer instructions?

No — employer reliance on a consensus standard does not replace manufacturer instructions; both should be followed, and mandatory OSHA rules still apply. Appendix C lists recommended standards, but you must also follow the equipment manufacturer’s operation, inspection, and maintenance instructions and the mandatory scaffold rules in Subpart L. See 1926 Subpart L App C for the list of consensus standards and ensure coordination with manufacturer guidance.

Under 1926 Subpart L App C, when should a construction employer consult the ANSI/SIA A92 standards listed in the appendix?

Employers should consult the listed ANSI/SIA A92 standards when selecting, operating, inspecting, maintaining, or training workers on aerial work platforms and related devices, as these standards provide detailed technical guidance. Appendix C identifies those consensus standards as helpful references; see 1926 Subpart L App C and use the standards to supplement compliance with the mandatory Subpart L rules.

Under 1926 Subpart L App C, do the listed ANSI/SIA standards cover both vehicle-mounted and self-propelled elevating platforms?

Yes — Appendix C includes ANSI/SIA standards that cover vehicle-mounted elevating devices (for example, ANSI/SIA A92.2-1990) and self-propelled elevating work platforms (for example, ANSI/SIA A92.6-1990). The appendix lists several A92 standards with different scopes; see the list in 1926 Subpart L App C to identify the specific standards relevant to the equipment you use.

Under 1926 Subpart L App C, does Appendix C replace the training requirements in Subpart L for scaffold users?

No — Appendix C does not replace mandatory training requirements in Subpart L; it only lists voluntary consensus standards that can inform training content. Employers must provide required training per the mandatory provisions of Subpart L, and they may use the listed standards as supplementary material. See 1926 Subpart L App C for the consensus standards list.

Under 1926 Subpart L App C, how should an employer use Appendix C when developing a written safety program for aerial lifts?

An employer should use Appendix C as a source of technical guidance and best practices to inform policies, procedures, and training in a written safety program, while ensuring the program meets all mandatory Subpart L requirements. Appendix C lists consensus standards such as the ANSI/SIA A92 series that can be incorporated into your program; consult 1926 Subpart L App C and cross-check with the mandatory Subpart L rules.

Under 1926 Subpart L App C, if an OSHA inspector cites a Subpart L violation, can I show compliance with a listed ANSI/SIA standard as a defense?

Showing compliance with a listed ANSI/SIA standard may help demonstrate that you followed recognized safe practices, but it is not an absolute defense if you failed to meet the mandatory Subpart L requirements. Appendix C provides non-mandatory references; you must also show compliance with the mandatory OSHA scaffolding rules. Refer to 1926 Subpart L App C for the consensus standards list.

Under 1926 Subpart L App C, are mast-climbing work platforms covered by the Appendix C list?

Yes — Appendix C explicitly lists ANSI/SIA A92.9-1993, which covers mast-climbing work platforms. You can find this standard title included in the appendix listing at 1926 Subpart L App C.

Under 1926 Subpart L App C, does Appendix C include standards for bridge inspection devices?

Yes — Appendix C includes ANSI/SIA A92.8-1993, titled "Vehicle-Mounted Bridge Inspection and Maintenance Devices," as one of the listed consensus standards. See the listing in 1926 Subpart L App C.

Under 1926 Subpart L App C, how current are the standard editions listed and should I be concerned about their publication dates?

Appendix C lists specific editions and years (for example, several A92 standards dated 1990 and 1993); because these are older editions, you should check for more recent revisions of the consensus standards and adopt newer, safer practices where appropriate while ensuring compliance with mandatory Subpart L rules. The appendix itself is a historical, non-mandatory list; see 1926 Subpart L App C for the editions cited.

Under 1926 Subpart L App C, if a consensus standard conflicts with a Subpart L mandatory requirement, which should I follow?

You must follow the mandatory Subpart L requirement if there is a conflict — Appendix C consensus standards are non-mandatory and cannot override OSHA regulations. If you encounter a conflict, comply with the mandatory rule in Subpart L and document the rationale; see 1926 Subpart L App C for the list of consensus standards.

Under 1926 Subpart L App C, can small employers rely on Appendix C to write simpler compliance procedures?

Small employers can use Appendix C as a helpful resource to simplify and organize safety procedures, but they still must meet all mandatory Subpart L requirements and should adapt any consensus standard guidance to their operations. Appendix C lists useful consensus standards to reference; consult 1926 Subpart L App C and ensure mandatory rules are fully implemented.

Under 1926 Subpart L App C, where can I find the exact titles and years of the national consensus standards relevant to scaffolds?

Appendix C provides the exact titles and publication years of the listed national consensus standards (for example, "ANSI/SIA A92.6-1990 Self-Propelled Elevating Work Platforms"). You can view the full list in 1926 Subpart L App C.

Under 1926 Subpart L App C, should safety committees include the consensus standards from Appendix C when performing inspections and audits?

Yes — including the Appendix C consensus standards in inspections and audits is a good practice because they provide technical detail and recommended practices that complement the mandatory Subpart L rules. Use the standards listed in Appendix C as supplemental checklists while ensuring you also verify compliance with the mandatory regulations; see 1926 Subpart L App C.