Michigan Makes AWP Operator Training Law

After two years in development, Michigan OSHA has made significant changes to its laws regarding aerial work platforms by updating and requiring aerial work platform training. MIOSHA’s AWP operator training laws will go into effect March 2008 for Part 32 of its construction standard and June 2008 for Part 58 of the general industry standard.

The changes made to MIOSH’s AWP regulations provide significant changes covering operator training, issuance of employee permits prior to operation, equipment inspections, and fall protection. The regulations also expand employer and employee responsibilities to include a requirement to provide training by a qualified person.

In addition to altering the verbiage used in the standards, the regulation also adds reference to the ANSI A92.2-2002, A92.3-2006, A92.5-2006, and A92.6-1999 standards. Note the references are specific to the construction of the aerial work platform and not incorporated in the training requirements.

Both the MIOSHA Part 32 construction safety standard and Part 58 general industry standard are nearly identical in training and permitting requirements for operators of AWPs. These regulations require that:

  • Employers provide each employee who will operate an AWP defined instructions, given by a qualified person on four defined areas listed in the regulation;
  • Detailed permitting requirements;
  • Permits are valid for three years and only valid for the employer who issued the permit; and
  • The manufacturer’s operating instructions and safety rules must be provided and maintained on the site.

Unlike federal OSHA, this regulation specifically requires AWP operator training and a permit must be carried by the trained operator or be available at the jobsite and displayed when requested by a department of labor representative. The permit must indicate the type of AWP the operator has been trained on (vehicle-mounted, manually propelled, boom-supported, and self-propelled) and other details defined in the regulation. A citation may be issued for lack of training even if no serious accident occurs.

Additionally, the standards specifically require the operator to perform a pre-start inspection before use on each shift, which includes a visual inspection, function testing of platform and ground controls, and a workplace inspection before and during use of the AWP. The regulation also requires the employer to comply with requirements to inspect and maintain each aerial work platform in accordance with the manufacturer’s operating or maintenance and repair manuals. Repairs are to be made by an authorized person.

Under the fall protection requirement, the regulation requires that the employer shall provide a safety harness with lanyard to be used by all occupants of boom-type lifts. It further allows for the use of a body belt with a restraint device with the lanyard when there is no fall exposure. The use of a fall arrest system is prohibited unless the aerial lift is designed to withstand the vertical and lateral loads caused by a fall arrest. It also requires the employer to provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.

Additionally, the regulation has a provision for exiting the platform “where elevated work areas are inaccessible or hazardous to reach.” It states that employees may exit the platform with the knowledge and consent of their employer.

To review all the changes in the regulations, visit www.michigan.gov/mioshastandards and go the “What’s New” section.

For a complete analysis of the MIOSHA AWP regulation changes, look for the Tony Groat’s article, “AWP Operator Training Becomes Law in Michigan” in the February 2009 issue of Lift and Access.