Scissor lift inspection requirements

Which OSHA rules cover scissor lifts

OSHA treats most scissor lifts as mobile scaffolds, not aerial lifts. Its hazard alert Working Safely with Scissor Lifts (OSHA 3842, 2016) says "Many scissor lifts are covered under OSHA's Scaffolding standard", and explains the difference: "Scissor lifts are different from aerial lifts because the lifting mechanism moves the work platform straight up and down using crossed beams functioning in a scissor-like fashion."

For construction, the alert lists the standards that apply:

• 1926.451, general requirements for scaffolds, including the inspection rule and guardrails.
• 1926.452, additional requirements for specific types of scaffold, including mobile scaffolds in 1926.452(w).
• 1926.454, training for anyone who works on, operates or inspects a scaffold.
• 1926.21, general safety training.

Guardrails are required either way: "Scissor lifts must have guardrails installed to prevent workers from falling (see 29 CFR 1926.451(g) or 29 CFR 1910.29(a)(3)(vii))." That's why the aerial lift rule's daily controls test (1926.453) is usually quoted for boom lifts and the scaffold inspection rule for scissor lifts. Testing the controls every day costs nothing, so do both.

Before each shift: the competent-person inspection

The scaffold rule requires a competent person to inspect the lift for visible defects before every work shift. 29 CFR 1926.451(f)(3): "Scaffolds and scaffold components shall be inspected for visible defects by a competent person before each work shift, and after any occurrence which could affect a scaffold's structural integrity." Paragraph (f)(4) then says any part "damaged or weakened such that its strength is less than that required" must be "immediately repaired or replaced, braced to meet those provisions, or removed from service until repaired."

A competent person is someone "capable of identifying existing and predictable hazards" who "has authorization to take prompt corrective measures to eliminate them" (1926.32(f)). If your operators do the shift inspection, make sure each one meets that definition: trained to recognize the machine's hazards, and allowed to take it out of service. See what is a competent person.

"After any occurrence" means looking again after the lift is struck by a vehicle or load, overloaded, driven into a hole or off an edge, or caught in high wind, before anyone goes back up.

ANSI A92 inspections for scissor lifts

Under the ANSI A92 standards, scissor lifts are MEWPs, with the same inspection cycle as boom lifts. As the manufacturer Genie summarizes it, a frequent inspection applies once a unit "has been in service for three months, or 150 hours, whichever comes first", and the annual inspection is due "no later than thirteen (13) months from the date of the prior annual inspection", by "a person(s) qualified as a mechanic on the specific type of aerial platform."

One walk-around can cover the first two rows, if it's done by a trained operator who meets the competent-person definition. The full ANSI picture is in MEWP inspection requirements.

What the manufacturer's instructions cover

OSHA points you to the manufacturer's manual for the details. Its alert says the manufacturer's maintenance and inspection instructions "will generally include how to: Test and inspect controls and components before each use. Ensure that guardrail systems are in good working condition. Verify that brakes once set will hold the scissor lift in position."

The alert adds limits worth checking every shift:

• Safety systems designed to stop the lift collapsing must be "maintained and not bypassed."
• The weight on the platform must never exceed the manufacturer's load rating.
• "Scissor lifts rated for outdoor use are generally limited to wind speeds below 28 miles per hour", so check the rating on your machine's plate.
• Work locations should keep at least 10 feet from power lines and other electrical sources.

What to check on a scissor lift before each shift

A scissor lift's pre-shift check is the scaffold inspection plus the manufacturer's pre-start and function tests. A typical list:

• Guardrails: top rails, midrails and toeboards secure; the entry gate or chain closes and latches.
• Platform: deck undamaged; the extension deck slides and locks.
• Scissor stack: arms, pins and retainers with no cracks, bends or missing pins.
• Hydraulics: no leaks at cylinders, hoses or fittings; fluid at the right level.
• Power: battery charged with clean, tight connections, or fuel and engine fluids on engine models.
• Base: tires and wheels sound; pothole guards deploy where fitted.
• Labels: decals and the capacity plate legible; the manual in its holder.
• Function tests: platform and ground controls, the emergency stop at both stations, emergency lowering, drive and steer, brakes that hold, the tilt alarm, the descent alarm and the horn.
• Workplace: a firm, level floor; no holes or drop-offs; clear overhead; at least 10 feet from power lines; wind within the rating.

Our free scissor lift inspection checklist has the full list to print or edit.

Why the inspection matters

The pre-shift inspection is where guardrails, brakes, the tilt alarm and the ground get checked, and those are what hurt people. OSHA's alert says that "over a one-year period, OSHA investigated ten preventable fatalities and more than 20 preventable injuries resulting from a variety of incidents involving scissor lifts", and that most "were the result of employers not addressing" three things: fall protection, stabilization and positioning.

Training for scissor lift operators and inspectors

OSHA's scaffold training rule covers both the people who work on a scissor lift and the people who inspect it. Under 1926.454, each employee who works on a scaffold must be trained "by a person qualified in the subject matter", and each employee involved in "erecting, disassembling, moving, operating, repairing, maintaining, or inspecting a scaffold" must be trained by a competent person. Retraining is required when the worksite or equipment changes, or when someone's work shows they haven't kept the skill. The alert adds that training must include "reporting any equipment defects or maintenance needs."

Records

OSHA's scaffold rule doesn't require a written record of the shift inspection; the ANSI frequent and annual inspections are recorded. A dated record of each shift check is still the only way to show it was done, and it tells you when a lift was last looked at before an incident.

Scissor lift checks on a phone

With CheckBadges, each scissor lift gets a QR sticker by the platform controls. The operator scans it with their own phone, with no app or login, and works through that lift's checklist, starting from our scissor and boom lift template. A failed item needs a note and can carry photos, emails you straight away, and warns the next operator who scans that lift until you mark it fixed. Every check is filed by machine with the operator's name and the time.