False Fall Protection
What’s the hazard here? Fall hazard. When employees are exposed to falls of greater than 4-feet in general industry settings and greater than 6-feet in construction settings, they must be protected from falling. That means they need fall protection, like personal fall arrest systems, harnesses, etc.
In this case, the employee was adequately protected from falling while she was standing on the floor of the aerial lift and within its guardrail system.
However, the moment this employee uses the guardrail system as a makeshift ladder, they are exposing themselves to a fall hazard.
How can this hazard be corrected? Removing more panels from the ceiling to allow for greater access to heights is one possible solution. A ladder tall enough to access the area could be another option. Ideally, the aerial lift would extend to a height sufficient to perform the required task.
Any laws around this? In the construction industry, 29 CFR 1926.453(b)(2)(iv) states that "Employees shall always stand firmly on the floor of the basket, and shall not sit or climb on the edge of the basket or use planks, ladders, or other devices for a work position." The general industry standard 29 CFR 1910.67(c)(2)(iv) states, “Employees shall always stand firmly on the floor of the basket, and shall not sit or climb on the edge of the basket or use planks, ladders, or other devices for a work position.”
Conversation starters: During safety audits, tool box talks, and pre-shift meetings, ask about the type of work and maintenance happening in a given day or week. Ask also about tools and equipment used to perform the work to give clues as to whether or not adequate tools and equipment are available and remember to ask for specifics on how the work will be performed safely.