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ANSI standards for scissor lifts and aerial devices

Summary A lift maker asked which OSHA and ANSI standards applied to scissor lifts. OSHA said its aerial device rule referenced ANSI A92.2 for covered vehicle-mounted devices and that scissor lifts complying with specified later ANSI standards did not appear to violate an OSHA standard, though unsafe employer use could still be cited. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1980-03-31
Date issued
March 31, 1980
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

March 31, 1980

Edwin M. Burk, P.E.
Vice President-General Manager
United States Waco Corp.
[Recipient address omitted]

Dear Mr. Burk:

This is in response to your recent inquiry concerning OSHA's requirements for scissor lifts and the applicability of ANSI A92.2-1969, and confirms a telephone conversation with Mr. William Simms of my staff.

29 CFR 1910.67(b)(1) states that unless otherwise provided in this section, aerial devices (aerial Lifts) acquired on or after July 1, 1975, shall be designed and constructed in conformance with applicable requirements of the American National Standard for "Vehicle Mounted Elevating and Rotating Work Platforms" ANSI A92.2-1969, including appendix. Aerial devices include the following types of vehicle-mounted aerial devices used to elevate personnel to jobsites above ground: (i) extensible boom platforms, (ii) aerial ladders, (iii) articulating boom platforms, (iv) vertical towers, and a combination of any of the above. The 29 CFR 1910.67 requirements including the reference to ANSI A92.2-1969 will be enforced until the section is modified in the future.

In regard to OSHA's position on the applicability of ANSI A92.2-1969 for Vehicle-Mounted Elevating and Rotating Aerial Devices, I have attached a copy of OSHA Instruction CPL 2-11A for your information.

It does appear that manufacturers of scissor lifts complying with either ANSI A92.3-1973 or ANSI A92.6-1979 and the manufacturer's operating instructions stating the restrictions and requirements for safety as required in each standard, would not be in violation of any OSHA standard. However, employers using the equipment in an unsafe manner may be cited in accordance with section 5(a)(1) of the Act.

If we may be of further assistance, please feel free to call or write.

Sincerely,
Grover C. Wrenn Director,
Federal Compliance and State Programs

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