While OSHA does not have a general industry standard that specifically addresses scissor lifts, the agency regards a scissor lift as a scaffold. This is specified in an August, 1, 2000, letter of interpretation (LOI). In that letter, the agency says that if the scissor lift has guardrails that meet OSHA requirements, that is all that is required for fall protection. In other words, employees do not have to tie-off in a scissor lift if it has guardrails.
OSHA further addresses this issue in an LOI dated July 21, 1998, which explains: “In regards to your specific question, when working from an elevated scissors lift (ANSI A92.6 series), a worker need only be protected from falling by a properly designed and maintained guardrail system. However, if the guardrail system is less than adequate, or the worker leaves the safety of the work platform, an additional fall protection device would be required. The general scaffolding fall protection provision found in 1926.451(g)(1)(vii) reads in part, “for all scaffolds not otherwise specified in this section, each employee shall be protected by the use of personal fall arrest systems or guardrails systems.”