Chapter 35 – Elevated Work – Mobile Elevating Work Platforms, Ladders, and Scaffolds

DRAFT

Approved by Matt Lindsay
Revised 1/24

35.1 Policy
35.2 Scope
35.3 Applicability
35.4 Exceptions
35.5 Roles and Responsibilities
35.6 Definitions
35.7 Required Work Processes

Work Process A. General Requirements
Work Process B. Procurement of Aerial Work Platforms, Ladders, or Scaffolding
Work Process C. Authorization and Qualification
Work Process D. Fall Protection
Work Process E. MEWP Inspections
Work Process F. Exiting Elevated Work Platform Plan
Work Process G. Qualified Climbers
Work Process H. Lifting Personnel Baskets
Work Process I. Stools and Stepladders
Work Process J. Window Washers
Work Process K. MEWP Rescue Plan

35.8 Source Requirements
35.9 Reference Documents
35.10 Appendices

Appendix A. Daily MEWP Inspection Checklist (One-Man and Scissor Lifts – Type 1 and Type 3, Group A)
Appendix B. Daily MEWP Inspection Checklist (Boom Lifts – Type 3, Group B)
Appendix C. Risk Assessment Form
Appendix D. LBNL Scaffolding Daily Inspection Checklist
Appendix E. Elevated Work Platform Exiting Plan

Note:
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35.1 Policy

Persons using Mobile Elevating Work Platforms (MEWPs), ladders, or scaffolds at Lawrence Berkeley National Laboratory (Berkeley Lab) must ensure that the equipment and structural provisions for accessing and working at elevated levels and for overhead movement of materials meet industry safety standards and comply with general industry safety orders (OSHA). The requirements for fall protection (see Chapter 30 Fall Protection Program) apply to work activities from elevated heights covered by the Elevated Work Program.

35.2 Scope

Berkeley Lab’s Elevated Work Program is implemented through planning, classroom training, and on-the-job-training. Implementation of the operational controls, hazard controls, and rescue procedures are established as applicable on the Berkeley Lab Fall Protection Permit and implemented in the field to control the risk of operational hazards while individuals are working at elevated heights.

35.3 Applicability

This program applies to work on any elevated work platform used to raise or lower workers to perform tasks at elevated heights, as well as work requiring the use of ladders and rolling scaffolds. At Berkeley Lab, it applies to:

Employees
Construction contractors
Non-construction subcontractors, vendors, and affiliates

35.4 Exceptions

None

35.5 Roles and Responsibilities

Role	Responsibilities
MEWP Manager	Is a qualified MEWP operator who has been designated as the individual responsible for the safe operation of a specific MEWP (MEWP Custodian)
Authorized Person (Operator)	Has a working understanding of Berkeley Lab’s Elevated Work Program and has the knowledge and training necessary to perform the job safely Must safely operate MEWPs for which they are qualified Becomes qualified by successfully completing EHS0223 Aerial Work Platform and EHS0222 Aerial Work Platform Practical (or the equivalent for subcontractors) and show proof of completing EHS276 Fall Protection training or the equivalent for subcontractors Must be authorized by his or her supervisor through an Employee Work Planning & Control (WPC) activity, Site Specific Safety Plan, or (for service subcontractors) the Subcontractor Job Hazards Analysis (sJHA) For ladder use (ladders >30 inches tall), must complete EHS0278 Ladder Safety Training (or the equivalent for subcontractors) and be authorized by his or her supervisor through an Employee WPC, Site Specific Safety Plan, or an sJHA. For scaffold use, must complete EHS0279 Scaffold Users Hazard Awareness (or the equivalent for subcontractors) and be authorized by an Employee WPC Activity, Site Specific Safety Plan, or an sJHA
Competent Person	Is responsible for identifying hazards by conducting hazard surveys; stopping or limiting work at the hazard site; supervising the selection and use of MEWP PPE; and verifying that equipment is compliant and workers are trained Participates in investigations, conducts equipment inspections, and removes damaged equipment from service Is authorized to take prompt corrective measures to eliminate or mitigate hazards and is knowledgeable in the application and use of equipment Is required to complete a training program approved by the Environment/Health/Safety Division and applicable program managers.
Elevated Work Subject Matter Expert (SME – Program Manager)	Responsible for providing technical expertise regarding elevated work to divisions and assist in the purchase of MEWPs, ladders, or scaffolds Responsible for validating equivalency in training for subcontractors and vendors Provides oversight and on-the-job training for fall protection competent person work group Provides metric and program self-assessments for managerial review
Line Management	Is responsible for ensuring that elevated work is performed safely and that MEWP operators as well as users of ladders or scaffolds are properly qualified and authorized
Fall Protection (SME – Program Manager)	Administers the Fall Protection Program

35.6 Definitions

Term	Definition
Mobile Elevating Work Platform (MEWP)	A mobile device that has an adjustable platform and is supported by a ground-level structure. Examples include boom lifts and scissor lifts.
American National Standards Institute (ANSI)	A private non-profit organization that oversees the development of voluntary consensus standards for products, services, processes, systems, and personnel in the United States. The standards applicable to MEWP are ANSI/SAIA-A92.20 Design, Calculations and Test Methods for Mobile Elevating Work Platforms (MEWPs); ANSI/SAIA A92.22 Safe Use of Mobile Elevating Work Platforms (MEWPs); ANSI/SAIA A92.24 Training Requirements for the Use, Operation, Inspection, Testing and Maintenance of Mobile Elevating Work Platforms (MEWPs). The standard applicable to Scaffolds is ANSI/ASSP A10.8-2019 Scaffolding Safety Requirements.
Anchorage	A secure point of attachment for lifelines, lanyards, or deceleration devices. Certified anchorage: An anchorage for fall arrest, work positioning, restraint, or rescue systems for which a Fall Protection Qualified Person has certified it as (a) capable of supporting forces that could be applied during a fall or (b) having met the criteria per ANSI Z359.2-2017 Non-certified Anchorage: A fall-arrest anchorage that a Fall Protection Competent Person judges to be capable of supporting the predetermined anchorage forces
Base	The relevant contact point of the aerial platform, ladder, or scaffold that forms its stability fulcrum (e.g., legs, wheels, casters, outriggers, stabilizers)
Boom	A cantilever beam that supports a platform
Extension Ladder	An extension ladder is a non-self-supporting portable ladder adjustable in length. It consists of two or more sections traveling in guides or brackets so arranged as to permit length adjustment. Its size is designated by the sum of the lengths of the sections measured along the side rails.
Guardrail System	A vertical barrier primarily intended to protect personnel from falling to lower levels consisting of a toprail, midrail, and their supports.
IWCA	International Window Cleaning Association
Ladder	An appliance usually consisting of two side rails joined at regular intervals by cross pieces — called steps, rungs, or cleats — on which a person may step while ascending or descending
Manufacturer	A person or entity that makes, builds, or produces an MEWP, ladder, or scaffold
Maximum Travel Height	The maximum platform height, or the most adverse configuration(s) affecting stability, for which travel is permitted by the manufacturer
Operation	Performance of an MEWP’s functions within the scope of its specifications and in accordance with the manufacturer’s instructions, the user’s work rules, and applicable government regulations
Operator	A qualified and authorized person who controls the movement, and pre-work inspection duties of an MEWP
Outrigger	Device(s) that increase stability and are capable of lifting and leveling
Platform	The portion of an MEWP intended for occupation by personnel and their necessary tools and materials
PPE	Personal Protective Equipment
Qualified Climber	A worker who performs any work activity that requires a worker to travel to a work position that is above 6 feet, and to use three points of contact on structures other than portable ladders before implementing an active fall protection system, e.g., a positioning device to perform work.
Qualified Person	A person who possesses a recognized degree, certificate, or professional standing; or who has successfully demonstrated by extensive knowledge, training, and experience his/her ability to solve or resolve problems related to the subject matter, the work, or the project
Scaffold	Any temporary elevated platform and its supporting structure used for supporting workers, materials, or both
Sectional Ladder	A sectional ladder is a non-self-supporting portable ladder, non-adjustable in length, consisting of two or more sections of ladder. Constructed that the sections may be combined to function as a single ladder. Its size is designated by the overall length of the assembled sections.
Side-Rolling Ladder	A side-rolling ladder is a semi-fixed ladder, non-adjustable in length, supported by attachments to a guide rail, which is generally fastened to shelving, the plane of the ladder being also its plane of motion.
Single Ladder	A single ladder is a non-self-supporting portable ladder, non-adjustable in length, consisting of one section. Its size is designated by the overall length of the side rail.
Single-Rail Ladder	A ladder with rungs, cleats, or steps mounted on a single-rail instead of the normal two rails used on most other ladders. *Single-rail ladders are not to be used at LBNL.
Special-Purpose Ladder	A special-purpose ladder is a portable ladder which represents either a modification or a combination of design or construction features in one of the general-purpose types of ladders previously defined, in order to adapt the ladder to special or specific uses.
Spur	The spiked climbing tools worn on the leg by tree or pole climbers. Also sometimes called “climbers,” “hooks,” “gaffs,” “irons,” or “spikes.” Tree-climbing spurs are typically fastened at the ankle with a synthetic strap and around the calf with a second strap that runs through a pad. “Gaff” is the appropriate term for the spike portion of the climbing spur. A set of climbing spurs is used with a tree-climbing harness and a flip line
Stability/Stable	A condition of an MEWP in which the sum of the movements that tend to overturn the unit is less than the sum of the movements that tend to resist overturning
Step Ladder	A step ladder is a self-supporting portable ladder, non-adjustable in length, having flat steps and a hinged back. Its size is designated by the overall length of the ladder measured along the front edge of the side rails.
Step stool	A self-supporting, foldable, portable ladder, non-adjustable in length, 32 inches or less in length, with flat steps and without a pail shelf, designed so that the ladder top cap as well as all steps can be climbed on. The side rails may extend above the top-cap but such extension is not considered as part of the step stool length.
SME	Subject matter expert
Training	Instruction, including information about potential hazards, to enable a trainee to become a qualified person for a task to be performed
Trestle Ladder	A trestle ladder is a self-supporting portable ladder, non-adjustable in length, consisting of two sections hinged at the top to form equal angles with the base. The size is designated by the length of the side rails measured along the front edge. Trestle ladders are not to be used at LBNL without Elevated Work Platform SME review.
Trolley Ladder	A trolley ladder is a semi-fixed ladder, non-adjustable in length, supported by attachments to an overhead track, the plane of the ladder being at right angles to the plane of motion.

35.7 Required Work Processes

Work Process A. General Requirements
Work Process B. Procurement of Aerial Work Platforms, Ladders, or Scaffolding
Work Process C. Authorization and Qualification
Work Process D. Fall Protection
Work Process E. MEWP Inspections
Work Process F. Exiting Elevated Work Platform Plan
Work Process G. Qualified Climbers
Work Process H. Lifting Personnel Baskets
Work Process I. Stools and Stepladders
Work Process J. Window Washers

Work Process K. MEWP Rescue Plan

Work Process A. General Requirements

General Requirements – Mobile Elevating Work Platforms (MEWPs)
1. MEWPs can be vertically adjusted by manual or powered means and may be self-propelled, towed, or manually moved. They include equipment such as scissor lifts, one-man-lifts, and boom lifts.
2. MEWPs are operated only under the following conditions:
  1. Employees using any MEWPs must be qualified in the proper and safe use of the equipment. One qualified operator must be stationed on the ground to perform any emergency duties. The ground operator may perform emergency duties for multiple MEWPs only if all MEWPs are within view and the ground operator is able to communicate with all platform operators. In addition to the platform operator, the ground operator will watch for ground and overhead obstructions and advise the platform operator of hazards they may encounter. The ground operator will prevent conflicts with other heavy equipment, traffic, workers, or pedestrians.
  2. Traveling with an MEWP at the Lab (excluding up and down movement), requires either use of an MEWP-trained spotter, or for the worker to exit the lift and drive the equipment from the ground or work surface. The spotter must be free from distractions and able to maintain a clear view of the area to ensure adequate clearance distance from hazards.
  3. All MEWPs must be inspected prior to each shift’s use and must not be operated if found to be unsafe. The inspection is recorded on the Daily MEWP Inspection Checklist.
  4. A Risk Assessment for each task is conducted and the results recorded on the Risk Assessment form on the back of the Daily MEWP Inspection Checklist. All applicable signatures must be included on the assessment form.
  5. A Fall Protection Permit must be filled out and rescue plan established.
  6. No elevated work platform may be used on an incline over 5% or in winds that exceed 25 mph unless it has been designed for such use by the manufacturer. MEWP are not to be used where lightning is within 10 miles.
  7. Provided they can be safely installed, wheel chocks shall be installed before using an aerial device on an incline.
  8. When used, outriggers shall be positioned on pads or a solid surface. All outriggers shall be equipped with hydraulic holding valves or mechanical locks at the outriggers.
3. All personnel on the work platform must wear an approved safety harness and adjustable lanyards properly restraining operators to an aerial platform anchorage device. (See Chapter 30 Fall Protection Program).
4. MEWP operators will not use self-retracting lifelines (SRL) as part of a personal fall-protection system (PFPS).
5. Only tools, equipment and materials that can be safely handled by workers within the work platform are allowed in the lift. Carrying materials outside the lift or materials that are larger than the platform is prohibited unless lift is manufactured for that purpose.
6. Workers must keep their feet firmly on the working surface and are not to climb on the toe board, mid-rail or top-rail of the MEWP. The use of stools, step ladders, or other means of achieving additional height is prohibited unless the aerial lift manufacturer has designed a device for this purpose.
7. All powered MEWPs must have working upper and lower control devices.
8. Outriggers, if provided, must be used as recommended by the manufacturer.
9. MEWPs equipped with outriggers must not be relocated while personnel are on the work platform in an elevated position and must not elevate personnel without the stability of outriggers.
10. All operators will have read the safety requirements contained in the equipment operator manual and in the Manual of Responsibilities prior to use and will follow these requirements at all times.
11. For distances greater than 500 feet of travel, a “chase vehicle” must be positioned a safe distance behind an MEWP when driven on the street. The chase vehicle driver must activate the vehicle’s hazard warning lights.
  
  The drivers of chase vehicles must be trained and approved flaggers. The chase vehicle drivers are tasked with preventing mobile equipment collision with other vehicles and objects, preventing unsafe passing of equipment by other vehicle drivers, and identifying and controlling hazards encountered while escorting the equipment that may adversely affect the operator, equipment, environment or other vehicles.
  
  Chase vehicle drivers will participate in the pre-task meeting and sign the risk assessment form.
12. In operations involving production of small debris, chips, etc., and the use of small tools and materials, and where persons are required to work or pass under the equipment, screens shall be required between toeboards and guardrails. The screen shall extend along the entire opening, shall consist of No. 18 gage U.S. Standard Wire 1/2 inch mesh, or equivalent.
13. Workers must stay at least 10 feet away from power lines with any part of their body, conductive object or any part of the MEWP. If work necessitates working within 10 feet, stop and consult with EHS electrical safety for requirements before proceeding.
14. The following shall be included in high voltage subcontractor specifications and/or contract documents: Work performed when using elevating work platforms or aerial devices in proximity to energized high voltage lines shall be in accordance with California Code of Regulations, Title 8, Articles 37 and 38 of the High-Voltage Electrical Safety Orders and the LBNL Electrical Safety Program.
Identification
1. The following must be permanently displayed and inspect for legibility on all MEWPs prior to use:
  1. Special warnings, cautions, or restrictions necessary for safe operations
  2. Make, model, and manufacturer’s name and address
  3. Rated workload capacity
  4. Maximum platform height
  5. Statement that device is in accordance with ANSI standards
  6. Instructions to study operating manual
  7. Special instruction e.g. exiting elevated platform , manual elevated platform lowering , maintenance, or attachment capacity instructions
  8. Proof of Maintenance record
2. Travel of MEWPs while employees, materials, tools, or equipment occupy that platform in an elevated position is permitted only if the following information is permanently attached to the unit:
  1. Maximum-rated load capacity at maximum height
  2. Maximum travel height
  3. Statement that the model has successfully passed the static stability test
General Requirements – Ladders

Portable wood ladders shall meet the design and construction requirements of ANSI A14.1-2007, American National Standard for Ladders – Wood Safety Requirements, which is hereby incorporated by reference.

Portable metal ladders shall meet the design and construction requirements of ANSI A14.2-2007, American National Standard for Ladders – Portable Metal – Safety Requirements, which is hereby incorporated by reference.

Fixed ladders shall meet the design and construction requirements of ANSI A14.3-2014 American National Standard for Fixed Ladder Safety Requirements (Including all amendments and changes through Reaffirmation Notice , 2018) which is hereby incorporated by reference.

Portable reinforced plastic ladders shall meet the design and construction requirements of Standard ANSI A14.5-2007, American National Standard for Ladders – Portable Reinforced Plastic – Safety Requirements, which is hereby incorporated by reference.

Safety hazards in the use of ladders can be substantially reduced by observing certain basic safety precautions noted below:

Ladders that exceed the following maximum lengths shall not be used:

Step Ladders, Trestle ladders, Extension trestle ladder base sections, Extension trestle ladder extensions, Trolley ladders or side rolling ladders longer than 20 ft
Two-section extension ladder (wood) or Three-section extension ladder (metal) longer than 60 ft
Two-section extension ladder (metal) longer than 48 ft
Two-section extension ladder (reinforced plastic) longer than 72 ft
Mason’s ladder longer than 40 ft
Single Ladders or Cleat Ladders longer than 30 ft
Painters’ step ladders longer than 12 ft

In addition, Two section extension ladders shall not be used when the overlap between the sections is less than the following minimum overlap:

Up to and including 32 ft, minimum overlap of 36 inches
Over 32 ft, and up to and including 36 ft, minimum overlap of 46 inches
Over 36 ft, and up to and including 48 ft, minimum overlap of 58 inches
Over 48 ft, and up to and including 60 ft, minimum overlap of 70 inches

Portable ladders
1. Ladders shall be selected and their use restricted to the purpose for which the ladder is designed. Single-rail ladders shall not be used.
2. All markings, warnings, and labels must be legible and the same or equivalent to manufacturer labeling.
3. Wooden ladders must not be painted, but may be coated with clear sealant or treated with nonirritating sealant to prevent decay.
4. Ladders must be stored to prevent weathering, blistering, or cracking.
5. Ladders shall be inspected by a qualified and authorized user for visible defects before each use and after any occurrence that could affect their safe use.
6. Ladders that have developed defects shall be withdrawn from service for repair or destruction; and tagged or marked as “Dangerous, Do Not Use” or with similar language. Ladders with broken or missing steps, rungs, cleats, safety feet, side rails, or other defects shall not be used.
7. Report any defective ladders to your supervisor.
8. Supervisors must ensure that any ladder reported as defective or unsafe is removed from service.
9. All metal ladders must be legibly marked with signs reading “Caution – Do Not Use Near Electrical Equipment.”
10. Portable straight and extension ladders must be equipped with slip-resistant shoes.
11. Non-self-supporting ladders such as single ladders and extension ladders shall, where possible, be used at such a pitch that the horizontal distance from the top support to the foot of the ladder is one-quarter of the working length of the ladder (the length along the ladder between the foot and the top support). The ladder shall be so placed as to prevent slipping, or it shall be tied, blocked, held, or otherwise secured to prevent slipping. Ladders shall not be used in a horizontal position as platforms, runways, or scaffolds unless designed for such use.
12. When two or more separate ladders are used to reach an elevated work area, the ladders shall be offset with a platform or landing between the ladders.
13. Tie-down straight or extension ladders when used to access high places.
14. The ladder base section of surface supported ladders shall be placed on a secure and level footing. When necessary, ladder levelers shall be used to achieve equal rail support on uneven surfaces. Ladders shall not be placed on boxes, barrels or other unstable bases to obtain additional height.
15. Ladders shall not be used on ice, snow or slippery surfaces unless suitable means to prevent slippage have been employed. The top of non-self-supporting ladders such as single and extension ladders shall be placed with the two rails supported equally, unless a single support attachment is provided and used.
16. Face ladders when ascending, descending, or working from a ladder.
17. Do not carry equipment or materials up a ladder in a way which prevents the safe use of ladders or prevents three points of contact.
18. Do not sit, kneel, step or stand on the pail shelf, top cap or the step below the top cap of a step ladder.
19. Do not stand and work on the top 3 rungs of a single or extension ladder.
20. Do not use a ladder as a scaffold.
21. Ladders shall not be placed in passageways, doorways, driveways, or any location where they may be displaced by activities being conducted on any other work, unless protected by barricades or guards or rendered inaccessible. Signage is required and must be placed on both sides of a doorway as applicable.
22. Do not place ladders on boxes or unstable bases to obtain additional height.
23. Do not climb higher than the second step from the top of a ladder.
24. When portable ladders are used for access to an upper landing surface, the side rails shall extend not less than 36 inches above the upper landing surface to which the ladder is used to gain access; or when such an extension is not possible, then the ladder shall be secured at its top to a rigid support that will not deflect, and a grasping device, such as a grab-rail, shall be provided to assist employees in mounting and dismounting the ladder. In no case shall the extension be such that ladder deflection under a load would, by itself, cause the ladder to slip off its support. A grasping device such as a grab-rail is not required where the employee is protected by a personal fall protection system in accordance with ES&H Manual Chapter 30 or during emergency rescue and emergency rescue training operations where it is not practical to extend a portable ladder 36 inches or more above the landing surface. When climbing or working with the body near the middle of the step or rung and shall not overreach from this position. When necessary to avoid overreaching, the employee shall descend and reposition the ladder. When it is not practical to work with the body near the middle of the step or rung, the ladder shall be secured to the top support, and the employee shall be protected by a personal fall protection system in accordance with ES&H Manual Chapter 30.
25. When a worker’s feet are six feet or more from the ground, and three points of contact (e.g., two feet and one hand) cannot be maintained and a platform or podium ladder is not feasible, a personal fall-arrest system is required in accordance with ES&H Manual Chapter 30.
Fixed ladders
1. Any fixed ladder of more than 20 feet to a maximum unbroken length of 30 feet installed before November 19, 2018 must be equipped with a personal fall arrest system, ladder safety system, cage, or well; No landing platform is required in these cases. All ladders and ladder safety devices must be maintained in a safe condition and be inspected at intervals determined by use and exposure. Inspection records must be maintained by the Facilities Division
2. Any fixed ladder of more than 20 feet to a maximum unbroken length of 30 feet installed on or after November 19, 2018, must be equipped with a personal fall arrest system or a ladder safety system;
3. When a fixed ladder, cage, or well, or any portion of a section thereof, is replaced, a personal fall arrest system or ladder safety system must be installed in at least that section of the fixed ladder, cage, or well where the replacement is located;
4. On or after November 18, 2036, all fixed ladders of more than 20 feet to a maximum unbroken length of 30 feet must be equipped with a personal fall arrest system or a ladder safety system.
5. All new fixed ladder installations must be designed and installed in compliance with American National Standard A14.3-2014 American National Standard for Fixed Ladder Safety Requirements (Including all amendments and changes through Reaffirmation Notice, 2018).
6. All fixed ladders shall be maintained in a safe condition.
7. All fixed ladders shall be inspected before use and regularly for damage or defects by qualified and authorized users, with the intervals between inspections being determined by use and exposure.
8. Ladders that have developed defects shall be withdrawn from service for repair or replacement; and tagged or marked as “Dangerous, Do Not Use” or with similar language. Ladders with broken or missing steps, rungs, , side rails, or other defects shall not be used.
9. Report any defective ladders to your supervisor.
10. Supervisors must ensure that any ladder reported as defective or unsafe is removed from service.
  
  Landing platforms
11. When ladders are used to ascend to heights exceeding 20 feet, landing platforms shall be provided as follows:

Where no cage, well, or ladder safety system is provided, landing platforms shall be provided for each 20 feet of height or fraction thereof.
Where a cage or well is provided and no ladder safety system is provided, landing platforms shall be provided for each 30 feet of height or fraction thereof.
Each ladder section shall be offset from adjacent ladder sections at each landing.
Where installation conditions (even for a short, unbroken length) require that adjacent sections be offset, landing platforms shall be provided at each offset.

Exceptions:

Ladders used primarily in construction operations, fire escape ladders, and ladders equipped with treads.
Ladders on high-voltage transmission towers, chimneys, smoke stack ladders, water tower ladders and similar fixed ladders on permanent installations which are used either infrequently or for emergency only, provided the employee who uses the ladder is supplied with and wears approved personal fall protection equipment, which can be utilized if a rest period is required.

Where an employee has to step a distance greater than 12 inches from the centerline of the rung of a ladder to the nearest edge of structure or equipment, a landing platform shall be provided. The minimum step-across distance shall be 2 1/2 inches.
All landing platforms shall be equipped with guardrails and toeboards, so arranged as to give safe access to the ladder. Platforms shall be not less than 24 inches in width and 30 inches in length.
One rung of any section of ladder shall be located at the level of the landing laterally served by the ladder. Where access to the landing is through the ladder, the same rung spacing as used on the ladder shall be used from the landing platform to the first rung below the landing.
Ladder Extensions. The side rails of through or side-step ladder extensions shall extend 3 1/2 feet above parapets and landings. For through ladder extensions, the rungs shall be omitted from the extension and shall have not less than 18 nor more than 24 inches clearance between rails. For side-step or offset fixed ladder sections, at landings, the side rails and rungs shall be carried to the next regular rung beyond or above the 3 1/2 feet minimum.
Grab Bars. Grab bars shall be spaced by a continuation of the rung spacing when they are located in the horizontal position. Vertical grab bars shall have the same spacing as the ladder side rails. Grab bar diameters shall be the equivalent of the round-rung diameters.
Ladder Safety Systems. Ladder safety systems may be used on tower, water tank, and chimney ladders over 20 feet in unbroken length in lieu of cage protection. No landing platform shall be required in these cases. All ladder safety systems shall meet the design requirements of the ladders which they serve.

General Requirements – Scaffolds. The following rules are required during the erection and use of scaffolds by all subcontractors:
1. A Qualified Person must supervise the erection of scaffolds.
2. Scaffold components must not be intermixed unless a qualified person can verify that they fit together without force, maintain structural stability, and have not been modified to do so.
3. Guardrail systems are required at heights over 6 feet except during erection and dismantling (where alternate means of fall protection is required) an must include end-rails
  
  “X” bracing is acceptable as a toprail if the intersection of the “X” occurs at 45 inches (plus or minus 3 inches) above the work platform, provided a horizontal rail is installed as a midrail between 19 and 25 inches above the work platform. The maximum vertical distance between the “X” brace members at the uprights shall not exceed 48 inches.
  
  “X” bracing is acceptable as a midrail if the intersection of the “X” falls between 20 inches and 30 inches above the work platform.
4. Toeboards are required where dropped object hazards exist. When materials are piled above the height of the toeboard, screens (or equivalent) are required.
5. At all times when next to shaft openings and/or windows, proper guardrails with toeboards must be installed regardless of the scaffold platform height from the floor.
6. Scaffolds shall be capable of supporting, without failure, their own weight and at least four times the maximum intended load.
7. Freestanding scaffolds with a height to base ratio of more than 4:1 (excluding guardrails) must be prevented from tipping by guys, ties, or braces.
8. Safe access and egress must be provided for all scaffolds either by properly secured ladders (with self-closing swing gate) or via scaffold frames that are specifically designed for access and egress.
9. Persons climbing or descending scaffolds must have both hands free for climbing.
10. Scaffolds over 125 feet must be designed by a registered professional engineer.
11. Outdoor scaffolds cannot be utilized during storms or high winds (as determined by competent person).
12. Construct scaffolds on a firm, stable base.
13. Where uplift may occur, scaffold post members must be locked together vertically by pins or other equivalent means.
14. Never erect a scaffold without a base using screw jacks and sole plate. Never put an open pipe end directly on concrete, a wood support, asphalt paving, or soil, as it may shift during use.
15. Provide fall protection at all heights above 6 feet during scaffold erection or while working on a yellow-tagged scaffold regardless of the type of scaffold if the yellow tag pertains to a fall hazard.
16. A Competent Person must inspect scaffolds before each use and after any occurrence that could affect the scaffold’s integrity. Completion of the daily checklist is required for all in-use scaffolds. See Appendix C, LBNL Scaffolding Daily Inspection Checklist.
17. When rolling scaffolds are in use, all wheels are locked.
18. For mobile scaffold towers the height must not exceed four times the minimum base dimensions. [Outrigger frames can be used as part of the minimum base dimension].
19. Tubular welded rolling scaffolds require a horizontal/diagonal brace.
20. All rolling scaffolds must be fully planked while in use, and guardrails with toeboards must be in place at heights of 6 feet or more.
21. Independent lifelines for each worker on a swing scaffold are required; they must be secured to a firm anchorage point separate from the scaffold anchorage.

Work Process B. Procurement of MEWPs, Ladders, or Scaffolding

Berkeley Lab divisions purchase their own MEWP, ladders, or scaffolding. The Elevated Work Program Subject Matter Expert (SME) assists division representatives in selecting the right equipment. The purchase of MEWPs is a controlled item for procurement purposes, and procurement personnel need to ensure that the SME approves all purchases or rentals.

Rental equipment should be of the type that matches the operator’s training certification or arrangements must be made with the vendor to supply equipment specific training to the operator upon delivery.

A fall protection matrix (permit) must be obtained for rental equipment prior to use.

Work Process C. Authorization and Qualification

The operation of MEWPs and the use of ladders or scaffolding (for Lab employees) are restricted to trained personnel who have completed Berkeley Lab-required training and who have been qualified to work with specific types of equipment in accordance with the requirements of this ES&H Manual Elevated Work — Aerial Work Platforms, Ladders, and Scaffolds program. Berkeley Lab employees must also be authorized through a specific WPC Activity to operate MEWPs or to use ladders or scaffolds.
All MEWP use at Berkeley Lab must be approved by the MEWPs manager for that particular equipment.
1. Before operating any given MEWPs on a new project, the operator must discuss the proposed use with the MEWP manager and obtain approval. Record this approval by signature on the initial LBNL Daily MEWP Inspection Checklist (Appendix A or B).
2. The MEWP manager will verify that the operator is currently trained and authorized for that particular MEWP and that the use will not conflict with hazardous conditions or other operations in the area, i.e., the Risk Assessment is completed and documented.
MEWPs may be operated by qualified service personnel who have been contracted to deliver, install, maintain, or repair them.
Contractors and vendors using MEWPs (rented or owned), scaffolds, or ladders must submit a Construction sJHA (part of the Site Specific Safety Plan/SSSP) or sJHA form identifying the appropriate work authorizations and regulatory requirements related to the safe operation/use of such equipment at Berkeley Lab. All MEWP operators, regardless of organizational origin, must meet the requirements of OSHA (Cal/OSHA for construction) and this Elevated Work — MEWPs, Ladders, and Scaffolds program.
Prospective MEWP operators must do the following:
1. The prospective Lab-employed operator must complete EHS0223 Aerial Work Platform Operator classroom training. Upon completion of this course, the individual may operate MEWPs under the direct supervision of an experienced MEWP operator for a period not to exceed 60 days.
2. When the prospective operator has acquired sufficient experience, he/she may contact the instructor to be examined on the operation of MEWPs to be used. If the candidate is to be certified on several types of MEWPs, a separate examination will be conducted for each MEWP. Upon receipt of the examination (evaluation form) and approval from the instructor, the EHS Training Office will record that the employee has completed the EHS0222 Aerial Work Platform Practical. A photocopy of the prospective operator’s valid California Driver’s License will be provided as a part of the EHS0222 evaluation. MEWP qualification will be updated via the employee’s WPC Activity by the employee’s supervisor.
3. Authorization is valid for five years from the evaluation date.
  1. Authorization to operate an MEWP will be revoked prior to the five year period upon:
    1. Deterioration of the operator’s performance or operation in an unsafe manner.
    2. An extended period (three years) without operation of a MEWP.
    3. Operator’s involvement in an incident or near miss incident with the MEWP.
  2. A qualified person must monitor, supervise and evaluate operators on a regular basis to ensure their proficiency.
  3. Upon renewal, the employee will be re-evaluated on each type of MEWP scheduled for requalification. There is no requirement to repeat the classroom training.
4. Proof of training must be provided to the operator.
5. The MEWP operator must provide instruction on the operation of controls to use in an emergency, safety rules, and how their actions could affect stability to non-qualified occupants of the platform.
Qualified Berkeley Lab MEWP Operators who have successfully completed EHS0223 and EHS0222 are eligible to operate only Laboratory MEWPs for which they have received specific practical training.
Supervisors of MEWP operators are required to complete EHS0223.
The use of an MEWP by subcontractors or vendors must be qualified by their employer. Qualifications must be documented and submitted to the Laboratory prior to any MEWP use.
Berkeley Lab employees who intend to use a ladder are required to take EHS0278 Ladder Safety Training. Subcontractors and vendors must provide evidence of equivalent training to the Elevated Work SME.
Berkeley Lab employees who intend to use a scaffold are required to take EHS0279 Scaffold Users Hazard Awareness. Subcontractors and vendors must provide evidence of equivalent training to the Elevated Work SME.

Work Process D. Fall Protection

The Berkeley Lab Fall Protection Matrix Permit is the planning document required for work from ladders and scaffolds at heights greater than 6 feet.
The prerequisite for EHS222 Aerial Work Platform is EHS276 Fall Protection Training. All MEWP operators at LBNL are required to be trained to use the appropriate fall protection equipment to safeguard against fall hazards. Subcontractors will be required to provide evidence of the equivalent EHS276 Fall Protection Training.

Work Process E. MEWP Inspections

Preventive Maintenance
1. Preventive maintenance must be scheduled and completed at intervals not to exceed that recommended by the manufacturer.
2. Copies of all inspections, preventive maintenance, and work reports must be retained for at least five years.
3. A documented annual inspection of the unit must occur at least every 13 months. The inspection must be performed by a person qualified as a mechanic and/or a competent person on the specific make and model of an aerial work platform or make and model of a ladder.
4. All Berkeley Lab MEWPs are to be labeled by the contracted service vendor with a certificate of inspection indicating an MEWP has received its required maintenance and service for both annual and frequent (in service for three months or 150 hours) inspections.

Daily (Pre-Start) Inspections: All MEWPs, ladders, and scaffolds must be inspected prior to use each shift.
1. MEWP operators are required to perform a pre-use inspection of the equipment as well as an inspection of the work area where they will be operating the MEWP. Inspections must include recommended items in the manufacturer’s manual.
The inspection must be documented on the daily inspection checklists shown in Appendix A (Daily MEWP Inspection Checklist — One-man Scissor Lifts – Type 1 and Type 3, Group A or Appendix B (Daily MEWP Inspection Checklist — Boom Lifts – Type 3, Group B). The checklists must be turned into and kept on file by the MEWP custodian.
A task specific risk assessment must be completed by a Qualified Person prior to use of a MEWP. The assessment is documented on the daily inspection checklist. The assessment will identify hazards associated with the specific task and location and appropriate controls identified and discussed with all persons involved in the use of the MEWP. The discussion will include details of the MEWP rescue plan.
Because MEWPs may become hazardous if maintenance is neglected or incomplete, all MEWPs must be routinely inspected and maintained by the Laboratory’s MEWP maintenance contractor. Contact the Facilities Fleet Operations for any questions concerning routine inspection or maintenance and requests for repairs. To report conditions that require emergency response (after dialing 911), contact the Plant Maintenance Technicians (PMT). Emergencies can include: collapse, tip over, spills or fuel leaks, pinch point incident, trapped operator or a mechanical failure leading to injury.
If MEWP components have been overloaded or stressed beyond capacity, or when there are other reasons to believe that there might be any damage to an MEWP, contact the Transportation Group in the Facilities Division for assistance when such issues are suspected.

Work Process F. Exiting or Entering an MEWP at Height

MEWPs are not specifically designed to transfer personnel from one level to another or for leaving the work platform. Exiting (or entering) a MEWP at height shall only be permitted through a procedure provided by the manufacturer or qualified person (and reviewed by an LBNL fall competent individual) that addresses the following:
1. Fall protection plan for workers entering or exiting the MEWP at height (requires 100% tie-off)
2. Controls in place for preventing dropped objects during transfer
3. Use of extending decks and gates
4. Distance between MEWP and transfer location (both vertically and horizontally).

* (See Appendix D. Elevated Work Platform Exiting Plan.)

Work Process G. Qualified Climbers

All work involving qualified climbers must be reviewed by both the Fall Protection SME and the Fall Protection Program Manager.
Qualified climbers are workers who perform any work activity that requires a worker to travel to a work position that is above 6 feet, and to use three points of contact on structures other than portable ladders before implementing an active fall protection system, e.g., a positioning device to perform work.
The Fall Protection Permit for all qualified climbing work will include the signature of the competent person for any of the following activities:
1. Riding a crane line into a position to cut down a tree
2. Climbing on communication towers or towers of any kind
3. Elevator construction and maintenance activities
4. Window-washing activities
5. Construction and maintenance activities

Work Process H. Lifting Personnel Baskets

Contact the Fall Protection SME and Elevated Work Platform SME prior to lifting personnel.

Work Process I. Stools and Stepladders

There are no general requirements for the use of stools or stepladders less than 30 inches high other than training. Consult your WPC Activity for training and authorization related to working on stools, stepladders, or ladders at heights less than 6 feet. Select the appropriate stool or stepladder for the task that will keep you safe and follow the manufacturer’s specifications.

Know the stool or stepladder’s capacity. Do not use a stool or stepladder that cannot support the intended load.
Inspect the stool or stepladder via the manufacturer’s specifications, similar to inspection of a regular ladder.
Ensure that slip-resistant devices such as rubber footing are in place.
Make sure the stool or stepladder is positioned firmly on the floor.
A personal fall protection system and fall protection permit will be required when a stool or stepladder is used near an additional hazard such as:
1. Next to an unprotected guardrail edge or any other unprotected edge
2. Next to unguarded machinery
3. Next to windows or skylights without a known impact rating
4. On any other elevated work surfaces e.g., MEWPs, ladders, scaffolds, or other equipment

Work Process J. Window Washers

Window-washing activities follow the guidelines of ANSI/IWCA (I-14 Window Cleaning Safety Standard) as well as all other requirements of the ES&H Manual.
All window washing operations, fall protection, and safety systems shall be designed and managed in compliance with Title 8 CCR, Division 1, Chapter 4, Subchapter 7. General Industry Safety Orders Group 1. General Physical Conditions and Structures Article 5. Window Cleaning (Sections 3281 – 3291).
Required qualifications, authorizations, and fall protection systems must be reviewed and approved by both the Fall Protection SME and the Managed Fall Protection Program Manager.
The LBNL Structural Engineer must review and authorize anchorage and fall protection system designs for all window-washing fall protection systems
Window washers cannot begin work without a permit signed by the Fall Protection Competent Person and Fall Protection Qualified Person/Structural Engineer.

Work Process K. MEWP Rescue Plan

The ground operator has primary responsibility for initiating and coordinating the MEWP Rescue Plan outlined below.
In the event of an injury or equipment malfunction when the occupants cannot self-rescue, the ground operator or other appropriate personnel must implement the following steps. These steps are non-inclusive and the response to an injury, incident or equipment malfunction will consider the specific details, safety and conditions of the event:
1. Notify 911 if serious injury or outside resources are necessary.
2. Determine if an electrical hazard is present. If present:
  1. Notify 911.
  2. Notify EHS Electrical Safety.
  3. Secure and prevent access to the area around the lift.
  4. Do not touch the lift
  5. De-energize the electrical source if possible (and if safe to do so).
3. If there is no electrical hazard, use ground controls or pneumatic release to lower the platform if this action will not cause or exacerbate any injury.
4. If ground controls do not work, or are inappropriate to use, consider rescue with another MEWP or ladder. Develop a specific rescue plan that considers the use of fall protection during transfer, weight capacity of the rescue lift, controls frozen or power switched off during transfer, and minimal distance between platforms.
5. In the case of a platform entanglement, the operator and occupants must be removed from the platform prior to any attempt to free the platform.
6. An MEWP that has tipped beyond its center of gravity must be stabilized and secured before attempting rescue.
7. Initiate Fall Rescue procedures if necessary.

35.8 Source Requirements

10 CFR 851.23, Worker Safety and Health Program, Safety and Health Standards
Title 8 CCR, Division 1, Chapter 4, Subchapter 4, Construction Safety Orders (for all construction safety unless 29 CFR 1926 Safety and Health Regulations for Construction is more strict) (Cal/OSHA Standard)

Article 17. Ramps, Runways, Stairwells, and Stairs (Sections 1623 – 1626)
Article 18. Access and Egress (Sections 1629 – 1631)
Article 19. Floor, Roof, and Wall Openings (Sections 1632 – 1633)
Article 20. Temporary Floors (Section 1635)
Article 21, Scaffold – General Requirements (Sections 1635.1–1637)
Article 22, Scaffolds – Various Types (Sections 1640–1655)
Article 23, Suspended Scaffolds (Sections 1658–1667)
Article 25, Ladders (Sections 1675–1678)
Title 8 CCR, Division 1, Chapter 4, Subchapter 7. General Industry Safety Orders (for all General Industry safety unless 29 CFR 1910, Occupational Safety and Health Standards for General Industry is more strict) (Cal/OSHA Standard)
- Group 1. General Physical Conditions and Structures (Sections 3207 – 3299)
- Group 3. General Plant Equipment and Special Operations (Sections 3420 – 3583)

International Window Cleaner Association IWCA i-14.1-20XX
ANSI Z359 Fall Protection Code
ANSI/SAIA A92.20, A92.22, and A92.24 2018 MEWP Standards
ANSI A14 Standards ANSI-ASC Safety Standards for Ladders (Sections Specifically incorporated in this Chapter).
ANSI A10 Construction Code
ANSI/ASSP A10.8-2019 Scaffolding Safety Requirements

35.9 Reference Documents

ES&H Manual Chapter 10, Construction Safety
ES&H Manual Chapter 30, Fall Protection Program
ANSI/SAIA A92.20, A92.22, and A92.24 2018 MEWP Standards
ANSI/ASSP A10.8-2019 Scaffolding Safety Requirements

35.10 Appendices

Appendix A. Daily MEWP Inspection Checklist (One-Man and Scissor Lifts – Type 1 and Type 3, Group A)
Appendix B. Daily MEWP Inspection Checklist (Boom Lifts – Type 3, Group B)
Appendix C. Risk Assessment Form
Appendix D. LBNL Scaffolding Daily Inspection Checklist
Appendix E. Elevated Work Platform Exiting Plan

Appendix A. Daily MEWP Inspection Checklist (One-Man and Scissor Lifts – Type 1 and Type 3, Group A)

Download the form here

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