The upcoming implementation of the new ANSI A92.22 Safe Use and A92.24 Training Standards for Mobile Elevating Work Platforms (MEWPs) in the United States is creating quite a bit of confusion in the industry. We’ll break down the responsibilities outlined in the new standards and the challenges presented by these changes. But first, who will be affected?
These new standards are placing a huge emphasis on the responsibilities of the user (typically, this is the employer). From the largest construction organizations to the smallest facility management team. Even a small contractor who only occasionally rents a MEWP will be affected.
Once the standards have been finalized and published, all entities will have one year to be in complete compliance with them. So let’s get started.
DEVELOPING A SAFE USE PROGRAM
To begin, the standards will require the user (employer) to develop a safe use program specific to MEWPs which must include, but not be limited to:
- Performing a site risk assessment to identify hazards, evaluate risk, develop control measures and communicate with all affected persons,
- The selection, provision and use of a suitable MEWP and associated equipment,
- Access, preparation and maintenance of the site to include an assessment that the support surface is adequate to support the weight of the MEWP,
- MEWP maintenance including inspections and repairs as required,
- Inform the operator of local site requirements and warn and provide the means to protect against identified hazards in the areas where the MEWP will be operated
- Have a trained and qualified supervisor to monitor the performance or the work of the operator to ensure compliance with provisions of the standards,
- Prevention of unauthorized use of the MEWP, and
- Safety of persons not involved in the operation of the MEWP.
As mentioned above, the risks associated with the task specific to MEWP operations must be identified. These might be associated with the location where the work is to be carried out, the nature of the MEWP, or the personnel, materials and equipment to be carried.
- Once the hazards and risks involved in the task have been identified, the procedures and measures required to eliminate or mitigate them must be identified and implemented.
- The risk assessment results are used to plan safe work procedures, including any contingencies required, in carrying out the identified tasks.
- Rescue planning is a necessary component of a risk assessment when working at height. There are situations that require prior planning to ensure a safe and timely rescue. I will talk more about that in a moment.
- The user is responsible for communicating the results of the risk assessment to all parties involved.
Before a job starts, and periodically throughout a long-term job, the risk assessment must be reviewed to determine if any components of the tasks or the work environment have changed, as well as the effect that it could have on the safety of the operation. If any modifications to the risk assessment are required, these must be communicated to everyone involved prior to resuming the job.
DEVELOPING A RESCUE PLAN
The user (employer) must also develop a written rescue plan that will be carried out in the case of machine breakdown, platform entanglement or fall from platform. The plan must be put in writing and become part of the company’s training manual. All occupants must receive training that explains the procedures to follow if they fall and await rescue or witness another worker’s fall. This plan must limit the time that a properly restrained worker hangs suspended in the air since the individual(s) may begin to suffer serious bodily injury after 15-20 minutes.
Rescue plans can include self- rescue by the person involved (using a self-rescue harness), assisted rescue by others in the work area (using the ground controls or a second MEWP), or technical rescue by emergency services. Operator training will remain very much as it is now with a few additions. The training must now also cover:
- Proper selection of the correct MEWP for the work to be performed.
- How to perform a workplace risk assessment, including rescue planning.
- Occupant training.
DIFFERENCES BETWEEN ANSI AND INTERNATIONAL STANDARDS
Although ANSI standards are becoming more similar to the international standard, there are still a few areas where there will be differences. For example, ANSI will allow qualified operators, who have already received proper training and are qualified to operate other MEWP’s, to self-familiarize on machines they have not yet operated. And, ANSI will not impose a specific retraining period for operators. It will be based upon the user’s evaluation of the operator’s capabilities.
Regardless, all current operators will need to be trained up to the new standards.
Another new requirement in the standards is supervisor training. The user (employer) must ensure that all personnel that directly supervise MEWP operators are trained in the following areas:
- Proper selection of the correct MEWP for the work to be performed;
- The rules, regulations and standards that apply to MEWPs, including the provisions for safe use and the work being performed;
- Potential hazards associated with use of MEWPs and the means to protect against identified hazards;
- Knowledge that the manufacturer’s operating manuals are an integral part of the equipment and need to be stored properly in the weather resistant compartment on the MEWP.
In other words, anyone who directly supervises a MEWP operator must also go through the general training that the operator is required to undergo. However, they will not be required to complete the hands-on training component.
Occupant training is also a new requirement. The MEWP operator must ensure that all occupants in the platform have a basic level of knowledge to work safely on the MEWP. They must cover:
- The requirement to use fall protection and the location of fall protection anchors
- Factors including how their actions could affect stability
- Safe use of any MEWP accessories that they are assigned to use
- Any site specific work procedures the occupants must follow related to the operation of the MEWP
- Hazards related to the task at hand and their avoidance
- Manufacturer’s warnings and instructions
- At least one of the occupants must be provided with the knowledge to operate the controls in an emergency where the operator cannot. This is emergency training only and does not constitute operator training.
MAINTENANCE & REPAIR PERSONNEL
And finally, users (employers) must ensure that maintenance and repair personnel are trained by a qualified person to inspect and maintain the MEWP, in accordance with the manufacturer’s recommendations and ANSI standards.
CONSIDERATIONS FOR RENTERS
In the case where a MEWP is being rented, arrangements must be made by the owner to identify the entity that will be responsible for the inspections and maintenance activities described in the standard. These include but are not limited to:
- Frequent Inspections — when the MEWP is put into service, has been out of service for three months, has been in service for three months or 150 hours, whichever comes first.
- Annual Inspections — performed no later than 13 months after the previous annual inspection, the annual inspection must be documented on the outside of the MEWP in the form of a decal or plate and must identify the person who performed the inspection and the date the inspection was performed.
Keep in mind that, although ANSI standards are voluntary, OSHA often adopts ANSI standards via “incorporation by reference”. When these standards are adopted or incorporated, they become part of the OSHA regulation and therefore compliance is mandatory. Not following the ANSI standards would be considered a violation of OSHA’s “General Duty” clause, which requires employers to keep the workplace “free from recognized hazards”.
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