Confined Space Compliance in California 

Stephen A Young CIHM, RSP

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What is this article about? The military? Raising children? Lack of organization? Being out of control? What? The answer is: A little bit of everything.

In each case, a lack of discipline hurts the success of whatever is being done. One of the first things we see when doing an inspection in a poorly-managed organization is shoddy housekeeping. Nothing is put away. There is no place to put anything away. Employees cannot find things. Trip hazards abound, and there is a myriad of substances on the floor to slip on.

In an undisciplined organization, correct safety performance does not matter until an accident occurs. Unsafe conditions are permitted to remain uncorrected. Unsafe acts either go unnoticed or people prefer not to deal with problem employees. No procedures for safe and efficient operations are in writing because no one wants to take the time to write out what needs to be done. All levels of the organization come to work each day, do what needs to be done to get the work completed, failing to ensure the work is done safely, efficiently, or even productively.

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Q: I have been informed by a fellow instructor that IVES indicates it is acceptable to use a tie off point inside an aerial lift basket, while working outside the aerial lift basket. Please correct me if I am mistaken, I think the other instructor is incorrect. Does IVES' aerial lift instructor training indicate this practice is OK?

A: I agree with you in that I also think it is a bad idea to tie off to the platform of an aerial lift when you are not actually in it. However, I have two interpretations from OSHA on the topic and I think you will see as I did after reading them that OSHA allows the practice as long as the capabilities/ratings of the anchor point are not exceeded should a fall occur (read the interpretations here and here). If this cannot be assured, then the person/operator should tie off to another suitable anchor point outside of the platform.

One point I like to make to discourage operators from doing this (or companies from allowing it) is, even though OSHA appears to allow the practice you will notice that each interpretation points back to not exceeding the load rating of the anchor point. Since it is the manufacturer that builds the anchor points to meet (or exceed) the minimum design and construction requirements, I can assure you that their calculations and/or tests used in certifying the anchor points do not include any provisions for operators falling from positions outside of the platform. I'm not stating this as a fact but if I were a manufacturer, I wouldn't. Would you?

Besides, being tied off to an anchor point that could potentially move independently from you moving is just a really bad idea and should be avoided.