Chapter 35


Approved by Matthew Rice
Revised 10/12

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. Inspections

35.8 Source Requirements
35.9 Reference Documents

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35.1 Policy

Persons using aerial work platforms, ladders, or rolling 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 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 aerial 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:

35.4 Exceptions


35.5 Roles and Responsibilities



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 aerial work platforms for which they are certified
  • To be an Authorized Person for aerial work platforms, an individual must successfully complete EHS0223 Aerial Work Platform and EHS0224 Aerial Work Platform Practical (or the equivalent for subcontractors)
  • Must be authorized by his or her supervisor through an Employee Job Hazards Analysis (JHA) or a Construction Job Hazards Analysis, or (for service subcontractors) the Subcontractor Job Hazards Analysis (sJHA)
  • For ladder use (ladders >30 inches tall), an Authorized Person must successfully complete EHS0278 Ladder Safety Training (or the equivalent for subcontractors) and be authorized by his or her supervisor through an Employee JHA, Construction JHA, or an sJHA.
  • For scaffold use, an Authorized Person must successfully complete EHS0279 Scaffold Users Hazard Awareness and be authorized by the supervisor either through an Employee JHA, Construction JHA, or an sJHA.

Competent Person

  • Responsible for identifying hazards by conducting hazard surveys; stopping or limiting work at the hazard site; supervising selection and use of aerial work platform PPE; and verifying that equipment is compliant and workers are trained
  • Participates in investigations, conducts equipment inspections, and removes damaged equipment from service
  • Authorized to take prompt corrective measures to eliminate or mitigate hazards and is knowledgeable in the application and use of equipment
  • Required to complete a training program approved by the Environment, Health, Safety, and Security (EHSS) Division and the Fall Protection Program administrator

Elevated Work Subject Matter Expert (SME)

  • Responsible for providing technical expertise regarding elevated work to divisions and assist in the purchase of aerial work platforms, ladders, or scaffolds
  • Responsible for validating equivalency in training for subcontractors and vendors

Line Management

Responsible for ensuring that elevated work is performed safely and that Aerial Work Platform (AWP) operators and users of ladders or scaffolds are properly qualified and authorized

35.6 Definitions



Aerial Work Platform

A mobile device that has an adjustable platform, supported from ground level by a structure. Examples include boom lifts and scissor lifts.

American National Standards Institute (ANSI)

  • The standards applicable to aerial lifts are ANSI/SIA-A92.5 Boom-Supported Elevating Work Platforms and ANSI/SIA-A92.6-2006 Self-Propelled Elevating Work Platforms.
  • ANSI works closely with the Scaffold Industry Association (SIA), an association of industry representatives that develop specific standards relating to aerial lifts. SIA serves as secretariat for the A92 standards.
  • ANSI/SIA standards consider the manufacturer’s operating manual to be an “integral’ part of an aerial lift. Both the ANSI/SIA standard and an operator’s manual for the specific unit are required to be stored in a weather-resistant storage compartment at all times.


A secure point of attachment for lifelines, lanyards, or deceleration devices. These points of attachment shall be independent of any anchorage being used to support or suspend platforms and be capable of supporting the employee attached to the anchorage system.

  • 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 Z359.2-2007
  • Noncertified Anchorage: A fall-arrest anchorage that a Fall Protection Competent Person judges to be capable of supporting the predetermined anchorage forces


The relevant contact point of the aerial platform, ladder, or scaffold that forms its stability fulcrum (e.g., legs, wheels, casters, outriggers, stabilizers)


A cantilever beam that supports a platform

Guardrail System

A vertical barrier primarily intended to protect personnel from falling to lower levels. A personal fall-protection system is not required in aerial lifts (e.g., scissor lifts) that do not have an installed anchorage system, but manufacturers direct operators to use the guardrail system as their primary form of fall protection.


A person or entity that makes, builds, or produces an aerial platform, 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


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


Performance of an aerial platform’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


A qualified person who controls the movement of an aerial platform


Device(s) that increase stability and are capable of lifting and leveling


The portion of an aerial platform intended for occupation by personnel and their necessary tools and materials

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


A condition of an aerial platform 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


Any temporary elevated platform and its supporting structure used for supporting workers, materials, or both


Instruction, including information about potential hazards, to enable a trainee to become a qualified person for a task to be performed


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. Inspections

Work Process A. General Requirements

  1. General Requirements – Aerial Work Platforms
    1. Aerial work platforms 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. Aerial work platforms are operated only under the following conditions:
      1. Employees using any aerial work platform must be certified in the proper and safe use of the equipment. One certified operator must be stationed on the ground to perform any emergency duties. The ground operator may perform emergency duties for multiple aerial work platforms.
      2. All aerial work platforms must be inspected prior to each shift's use and must not be operated if found to be unsafe.
      3. No elevating work platform may be used on an incline over 5% or in winds that exceed 25 mph unless recommended for such use by the manufacturer.
    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 Fall Protection Program)
    4. All powered aerial work platforms must have working upper and lower control devices.
    5. Outriggers, if provided, must be used as recommended by the manufacturer.
    6. Aerial work platforms 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.
    7. Aerial lift operators will not use self-retracting lifelines (SRL) as part of a personal fall-protection system (PFPS) unless the use of self-retracting lifelines has been authorized by the elevated work platform’s manufacturer.
  2. Identification
    1. The following must be permanently displayed on all aerial work platforms:
      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 instructions
    2. Travel of aerial work platforms 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
  3. General Requirements – Ladders
    1. Safety hazards in the use of ladders can be substantially reduced by observing certain basic safety precautions noted below:
      1. Painters' stepladders longer than 3.7 m (12 ft) must not be used.
      2. All markings, warnings, and labels (as originally applied) must be legible.
      3. Wooden ladders must not be painted.
      4. Ladders must be stored to prevent weathering, blistering, or cracking.
      5. All metal ladders must be legibly marked with signs reading "Caution – Do Not Use Near Electrical Equipment."
      6. Portable straight and extension ladders must be equipped with slip-resistant shoes.
      7. Straight or extension ladders must be placed against a support at an angle such that the distance from the ladder base to the base of the support is one-fourth the working length of the ladder.
      8. Lash straight or extension ladders when used to access high places.
      9. Face ladders when ascending or descending.
      10. Do not use a ladder as a scaffold.
      11. Do not place a ladder in front of a doorway, unless the door is blocked open, locked, or guarded.
      12. Do not place ladders on boxes or unstable bases to obtain additional height.
      13. Do not climb higher than the second step from the top of a ladder.
      14. Ladders with broken rungs or missing steps must not be used.
      15. Inspect all ladders before use.
      16. Report any defective ladders to your supervisor.
      17. Supervisors must ensure that any ladder reported as defective or unsafe is removed from service.
    2. 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, a fall-arrest system is required. See Fall Protection Program.
  4. General Requirements – Scaffolds. The following rules are required during the erection and use of scaffolds by all subcontractors:
    1. A competent person must supervise the erection of scaffolds
    2. When rolling scaffolds are being used, wheels are locked.
    3. Tubular welded rolling scaffolds require a horizontal/diagonal brace.
    4. All rolling scaffolds must be fully planked while in use, and guardrails with toe boards must be in place at heights of 6 feet or more.
    5. At all times when next to shaft openings and/or windows, proper guardrails with toe boards must be installed regardless of the scaffold platform height from the floor.
    6. Properly secured ladders must be provided for all scaffolds.
    7. Cross bracing does not take the place of a guardrail.
    8. Guardrail systems include end-rails on all scaffolds.
    9. 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.
    10. Tie off or use outriggers on a scaffold higher than four times its minimum base length.
    11. Construct scaffolds on a firm, stable base.
    12. 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.
    13. Provide fall protection at all heights above 6 feet regardless of the type of scaffold.

Work Process B. Procurement of Aerial Work Platforms, Ladders, or Scaffolding

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

Work Process C. Authorization and Qualification

  1. The operation of aerial work platforms (AWP) and the use of ladders or scaffolding are restricted to trained personnel who have completed training required by Berkeley Lab and who have been certified for specific types of equipment in accordance with the requirements of the Elevated Work Program. Berkeley Lab employees must also be authorized through their Employee JHA to operate AWPs or to use ladders or scaffolds.
  2. All AWP use at Berkeley Lab must be approved by the AWP manager for that particular equipment.
    1. The AWP manager is a qualified AWP operator who has been designated as the individual responsible for the safe operation of a specific AWP.
    2. Before operating any given AWP for the first time, the operator must discuss the proposed use with the AWP manager and obtain approval.
    3. The AWP manager will verify that the operator is familiar with the controls for that particular AWP and that the use will not conflict with other operations in the area.
  3. AWPs may be operated by qualified service personnel who have been contracted to install, maintain, or repair them.
  4. Contractors and vendors required to use aerial lifts (rented or owned), scaffolds, or ladders must submit an sJHA form identifying the appropriate work authorizations and regulatory requirement related to safe operation/use of such equipment at Berkeley Lab. All aerial lift operators, regardless of organizational origin, must meet the requirements of OSHA (CAL OSHA for construction) and the Elevated Work Program.
  5. Prospective AWP operators must do the following:
    1. Complete an AWP application package (Appendix A), which contains the following:
      1. Identification of the specific types of AWPs to be operated by the employee.
      2. A copy of a current, valid driver’s license. This is required because AWPs frequently operate on Laboratory roads. Berkeley Lab AWP operators must maintain a valid driver’s license at all time.
      3. Identification of a currently licensed Berkeley Lab AWP operator who will provide on-the-job training and close supervision of all AWP use during a learner’s permit period.
      4. Signature of the licensed AWP operator to verify agreement to provide the on-the-job training (OJT).
      5. Signature of the prospective AWP operator’s supervisor. The signature verifies that the employee will be required to operate the identified AWPs as part of his/her employment at Berkeley Lab. The certification is not valid for any other purpose. The supervisor’s signature also ratifies the designation of the licensed AWP operator as a mentor and task supervisor during the learner’s permit period.
    2. The operator must complete EHS0223 Aerial Work Platform operator classroom training. Upon completion of this course, a learner’s permit is issued when needed, and the individual may operate AWPs under the direct supervision of the experienced AWP operator identified on the application. The learner’s permit will expire no later than 60 days from the date of issuance.
    3. When the prospective operator has acquired sufficient experience, he/she may contact the instructor to be examined on the operation of AWPs to be used. If the candidate is to be certified on several types of AWPs, a separate examination will be conducted for each AWP. Upon receipt of the examination certification from the instructor, the EHSS Training Office will record that the employee has completed the EHS0222 Aerial Work Platform Practical and will issue a permit to operate the pertinent AWPs. The certification will be valid for no more than three years.
    4. The AWP certification must be renewed whenever the operator is observed to operate an AWP in an unsafe manner, whenever the operator is involved in an AWP accident, and regardless of record at least once every three years.
      1. Note that the certification will be revoked or suspended by the AWP program manager in case of an accident or unsafe operation of the AWP. At renewal, the operator must complete an AWP application with a copy of his or her valid driver’s license. The employee will then be re-evaluated on each type of AWP to be covered by the recertification. There is no requirement to repeat the classroom training.
  6. Certified Berkeley Lab Aerial Lift Operators who have successfully completed EHS0223 and EHS0222 are eligible to operate only Laboratory aerial work platforms for which they have received specific practical training.
  7. Subcontractors and vendors must be qualified by their employer to safely operate the AWP they are using. Qualifications must be documented and submitted to the Laboratory prior to any AWP use.
  8. Berkeley Lab employees who intend to use a ladder >30 inches in height are required to take EHS0278 Ladder Safety Training. Subcontractors and vendors must provide evidence of equivalent training to the Elevated Work SME.
  9. 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

  1. The Berkeley Lab Fall Protection Permit is the planning document required for elevated work on aerial work platforms (AWPs) and work from ladders and scaffolds at heights greater than 6 feet.
  2. Contractors, affiliates, and vendors who prefer to use the Laboratory’s Fall Protection Permit instead of a company-prepared sJHA for AWP operations must read and sign a Berkeley Lab Fall Protection Permit Acceptance Letter. (See Appendix B)
  3. For more information, see the Matrix of Required Written Fall Protection Plans and How to Complete the Berkeley Lab Fall Protection Matrix in the Fall Protection Program.

Work Process E. Inspections

Daily (Pre-Start) Inspections: All aerial work platforms (AWPs), ladders, and scaffolds must be inspected prior to use by each shift.

  1. For AWPs, the inspector must sign and date the logbook and note any deficiencies. Inspections must include recommended items in the manufacturer's manual.
    1. Preventive Maintenance: All units must receive preventive maintenance at intervals no longer than is recommended in the manufacturer's manual.
    2. Copies of all inspections, preventive maintenance, and work reports must be retained for at least five years.
    3. An annual inspection of the unit must occur at least every 13 months. The inspection must be performed by a person qualified as a mechanic on the specific make and model of an aerial work platform.
    4. All Berkeley Lab AWPs are labeled with a certificate of inspection indicating an AWP has received its required maintenance and service for both annual and frequent (in service for three months or 150 hours) inspections.
      1. AWP 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 AWP.
  2. The inspection must be documented on the daily inspection checklists shown in Appendix C and Appendix D, and the checklists must be kept on file by the AWP custodian.
  3. Because aerial work platforms may become hazardous if maintenance is neglected or incomplete, all AWPs must be routinely inspected and maintained by the Laboratory’s AWP maintenance contractor. Contact the Facilities Transportation Group at ext. 5404 for any questions concerning routine inspection or maintenance, or to report conditions that require repair or emergency maintenance.
  4. If AWP components have been overloaded or stressed beyond capacity, or when there are other reasons to believe that there might be any damage to an aerial work platform, contact the Transportation Group in the Facilities Division for assistance when such issues are suspected.

 35.8 Source Requirements

35.9 Reference Documents


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