Letter to the Editor: Measuring up the "Six Foot Rule"

Editor's note: Jeff Stachowiak's letter has been written in response to a guest column that ran in the Oct. 4 issue of Lift and Access 360 in which Les Knoll discussed the myth of the six-foot rule. Knoll called for others to comment and share other aerial work platform operational myths. Stachowiak, the Safety and Training Manager for Sunbelt Rentals, offered the following comments to clear up the issue even further.

In his column, “Urban Myths”, Les Knoll states: "Like many myths and legends, this one (the Six Foot Rule) is based on facts, but remains far from the actual truth. This 'Six Foot Rule' spawns from actual regulations for stationary scaffolding that state that fall protection and tie-off is not required unless you are more than six feet off the ground."

Actually this is also an urban myth. The OSHA standards for scaffolding can be found in 1926, Subpart L specifically. 1926.451(g)(1) reads: "'Fall protection.' 1926.451(g)(1) Each employee on a scaffold more than 10 feet (3.1 m) above a lower level shall be protected from falling to that lower level. Paragraphs (g)(1)(i) through (vii) of this section establish the types of fall protection to be provided to the employees on each type of scaffold. Paragraph (g)(2) of this section addresses fall protection for scaffold erectors and dismantlers."

So, the OSHA Scaffold regulations states 10 feet for scaffold fall protection, not six feet. The six foot regulation is from OSHA 1926 Subpart M Fall Protection and states: "1926.501(b)(1) 'Unprotected sides and edges.' Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is six feet or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems."

The real reason this OSHA regulation does not apply to aerial lifts is found in OSHA 1926 Subpart M, which can be found below:

1926.500(a) Scope and application. 1926.500(a)(1) This subpart sets forth requirements and criteria for fall protection in construction workplaces covered under 29 CFR part 1926. Exception: The provisions of this subpart do not apply when employees are making an inspection, investigation, or assessment of workplace conditions prior to the actual start of construction work or after all construction work has been completed.

1926.500(a)(2) Section 1926.501 sets forth those workplaces, conditions, operations, and circumstances for which fall protection shall be provided except as follows:

  • 1926.500(a)(2)(i) Requirements relating to fall protection for employees working on scaffolds are provided in subpart L of this part.
  • 1926.500(a)(2)(ii) Requirements relating to fall protection for employees working on certain cranes and derricks are provided in subpart N of this part.
  • 1926.500(a)(2)(iii) Fall protection requirements for employees performing steel erection work (except for towers and tanks) are provided in subpart R of this part.
  • 1926.500(a)(2)(iv) Section 1926.502 does not apply to the erection of tanks and communication and broadcast towers. (Note: Section 1926.104 sets the criteria for body belts, lanyards and lifelines used for fall protection during tank and communication and broadcast tower erection. Paragraphs (b),(c) and (f) of 1926.107 provide definitions for the pertinent terms.)
  • 1926.500(a)(2)(v) Requirements relating to fall protection for employees engaged in the erection of tanks and communication and broadcast towers are provided in 1926.105.
  • 1926.500(a)(2)(vi) Requirements relating to fall protection for employees engaged in the construction of electric transmission and distribution lines and equipment are provided in subpart V of this part.
  • 1926.500(a)(2)(vii) Requirements relating to fall protection for employees working on stairways and ladders are provided in subpart X of this part.

As you can see, the whole thing is really complicated. OSHA states 10 feet for fall protection in the Scaffold standard. The OSHA regulation related to fall protection, where the six foot rule is, states that these fall protection standards do not apply to scaffolds. This whole thing was even more complicated when OSHA released the Fall Protection standard in February 1995 and then the Scaffold standard much later in November 1996. Everyone freaked out about scaffolding erectors because the general feeling was that they needed to start using personal fall protection while building scaffolding. However, most never bothered to read the first part of the Fall Protection standard "Scope and Applications" as stated above that says this standard doesn't apply to scaffolds.

I hope this clears up the “Six Foot Rule” urban myth.


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