ANSI/SAIA A92 FAQ
Frequently Asked Question(s)
HOUSTON ANSI IS ESTABLISHED
1918, The American Engineering Standards Committee (AESC) was established. The AESC later adopted the name American Nation Standards Institute (ANSI) in 1969. While men and woman across the globe watched in anticipation the first steps man took on the moon. ANSI was hard at work developing the standards to which made the construction of the lunar lander possible. With the birth of ANSI came the revolutionary public review process and formation of the ANSI Board of Standards review (BSR).
The A92 Main body is 1 of 240 voluntary consensus standard bodies accredited by ANSI. This is an ANS voting group. The inclusiveness and integrity of the ANS process encourages participation by the broadest range of subject-matter experts, resulting in high-quality standards that protect the public and foster fair commerce and innovation.
American National Standard (ANS) is a voluntary consensus standard that is developed in accordance with the ANSI Essential Requirements: Due process requirements for American National Standards and subject to ANSI’s neutral oversight and approval. These requirements are designed to ensure that development of American National Standards is a fair and responsive process that is open to open to all directly and materially affected parties.
Due process means that any party (organization, company, government agency, individual, etc.) with a direct and material interest has a right to participate by: a) expressing a position and its basis, b) having that position considered, and c) having the right to appeal. Due process allows for equity and fair play.
ANSI Board of Standards Review (BSR) is responsible for approving American National Standards and acting on proposals to revise, reaffirm and withdraw American National Standards. The ANSI Board of Standards Review (BSR) reviews standards submitted to ANSI with unresolved objections on
record. This includes negative votes from the consensus body as well as public review comments.
The BSR before a standard means that it has completed its final review and is an approved standard. However it is not required that an ANS secretariat place the BSR insignia in front of the standard title.
The BSR is bound by the Operating Procedures of the ANSI Board of Standards Review (BSR)
(ASC) stands for ANSI - Accredited Standard Developer.
A number of ANSI and other industry consensus standards have been adopted as OSHA requirements. 29 CFR 1926.453 Aerial Lifts (previously numbered §1926.556), which is part of OSHA's construction scaffolding standard, Part 1926 Subpart L, is one example where OSHA incorporated by reference an ANSI standard. This provision, which was originally promulgated under the Construction Safety Act and then adopted as an OSHA standard in 1971, requires that aerial lifts be designed and constructed in accordance with ANSI A92.2-1969, titled Vehicle Mounted Elevating and Rotating Work Platforms.
Industry consensus standards can also play a role in evaluating employer responsibilities under section 5(a)(1) of the OSH Act, also known as the General Duty Clause. That provision requires employers to:
"furnish to each of [its] employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to [its] employees."
Industry consensus standards can be evidence that an industry recognizes a hazard and that there are feasible means of correcting the hazard.
Yes, Director - Russell B. Swanson Explains why in his 2005 response regarding the 1926.453 standards.
Under OSHA's de minimis policy, where OSHA has adopted an earlier consensus standard, employers who are in compliance with the updated version will not be cited for a violation of the old version as long as the new one is at least equally protective.
Remember, though, that where an OSHA standard incorporates an earlier consensus standard, the only way the OSHA standard can be changed to adopt the new version is through rulemaking. For example, as stated above, the aerial lift standard references ANSI A92.2-1969. Even though ANSI A92.2 has been revised, the OSHA aerial lift standard continues to require only compliance with the 1969 standard.
Subpart L, which was published in 1996, contains a non-mandatory appendix that lists the A92-1990 and 1993 consensus standards that are considered to provide employee protection equivalent to ANSI A92.2-1969. Appendix C reflects the proliferation of equipment-specific ANSI standards since the adoption of the 1969 document. Employers complying with these later versions are considered to have provided protection equivalent to the 1969 requirements.
Yes, The BSR determined that the A92 standards as currently written violate the Commercial Terms Policy. Tutus company representative on the main committee identified several sole source concerns and brought examples of other language that needed to be reviewed. As a result of the BSR agreeing with the arguments raised by Forrest Hester in the 2019 hearing. The SAIA formed a commercial terms ad hoc to review the standards in their entirety.
The BSR determined that the A92 standards as currently written violate the Commercial Terms Policy insofar as they require that modifications or additions to a MEWP be made only with the permission of the manufacturer. Although the standards recognize an exception in the case where the manufacturer is no longer in existence (in which case "modification to a MEWP shall be made under the direction of an engineer with expertise in MEWPs"), the BSR determined that the exception was too narrow and that, in order to come into compliance with the Commercial Terms Policy, the standard would have to be revised to allow for experienced alternatives to perform modifications to the MEWP -- even in the case where the manufacturer is still in existence.
The question makes an incorrect assumption. The standard no longer requires written permission of the manufacturer. The first line of 6.2.2 states: “Modifications to a MEWP may be made by the owner, such modifications shall be subject to the applicable requirements set forth in this Standard”. It follows with a requirement that the manual state that modifications should only be made with written permission of the manufacturer. According to the standard “The use of the word “should” is to be understood as advisory, and having the same effect as "recommended." Thus, the standard recommends or advises that written permission be obtained from the manufacturer, it does not require it.
Response by,
Joshua Chard, Ph.D.
ASC A92 Chair
Global Rental Co., Inc. – a subsidiary of Altec, Inc.
The question makes an incorrect assumption. The manufacturer does not have the power to veto a requested alternative. As stated above, seeking the approval of the manufacturer is a recommendation or advice. The standard does in fact allow for a meaningful alternative. “Where the manufacturer / remanufacturer's approval cannot be obtained,” (by either failure to approve or by denying approval) “permission to perform modifications may be granted by an equivalent entity after analysis and approval of an engineer.”
Response by,
Joshua Chard, Ph.D.
ASC A92 Chair
Global Rental Co., Inc. – a subsidiary of Altec, Inc.
No. The question makes an incorrect assumption. The owner is not required to wait for the manufacturer’s permission. The owner is recommended or advised to seek the manufacturer’s permission, this is not a requirement. An owner may have valid reasons for using an alternative path to approval such as a manufacturer that is no longer in existence, is unresponsive, or denies a request. They can still modify using and equivalent entity option to approve
modifications.
Response by,
Joshua Chard, Ph.D.
ASC A92 Chair
Global Rental Co., Inc. – a subsidiary of Altec, Inc.
Equivalent Entity: An organization, agency, company or individual who, by possession of an appropriate technical degree, certificate, professional standing, or skill, and who, by knowledge, training, and/or experience, has demonstrated the ability to deal with the problems relating to
the subject matter, the work, or the project.
Although it is not the responsibility of the ASC A92 to identify equivalent entities, in an attempt to answer the question of the BSR, the respondent would note: The A92 series of standards are voluntary standards to which entities designate compliance based upon their own review of the requirements. The forward states “The use of American National Standards is completely voluntary; their existence does not in any respect preclude anyone, whether he has approved the standard or not, from manufacturing, marketing, purchasing, or using products, or procedures not conforming to the standards.” With that said, the following entities are ASC A92 members and have self-reported themselves as consultants with expertise in the subject matter. Many of the representatives of these entities are also engineers.
Arrowhead Product Development, Inc
Blazing Technologies
Brewington & Company
Eckstine and Associates, Inc
Equipment Consultant Services Unlimited, Inc
Equipment Safety Consultants
Eric A. Schmidt, P.E
Evulich & Associates
Ives Training & Compliance Group Inc
Merrifield Safety Consulting LLC
Reynolds Engineering Services Inc
RLH Consulting LLC
Utility Truck Equipment & Parts LLC
Vollmer-Gray Engineering
Response by,
Joshua Chard, Ph.D.
ASC A92 Chair
Global Rental Co., Inc. – a subsidiary of Altec, Inc.
The owner is not required to wait for the manufacturer’s permission. The owner is recommended or advised to seek the manufacturer’s permission, this is not a requirement. An owner may have valid reasons for using an alternative path to approval such as using and equivalent entity to approve modifications. Where the owner does seek permission from the manufacturer, they must determine at what point the manufacturer/remanufacturer's approval cannot be obtained, based upon their own needs. The owner can then, or at any time seek permission to perform modifications from an equivalent entity after analysis and approval of an engineer.
Response by,
Joshua Chard, Ph.D.
ASC A92 Chair
Global Rental Co., Inc. – a subsidiary of Altec, Inc.
It is not required for the ASC A92 to identify a period of time to wait, as seeking the permission of the manufacturer is no longer required, only advised. The A92 series of standards are voluntary standards to which entities designate compliance based upon their own review of the requirements. The forward states “The use of American National Standards is completely voluntary; their existence does not in any respect preclude anyone, whether he has approved the standard or not, from manufacturing, marketing, purchasing, or using products, or procedures not conforming to the standards.” The appellant has provided evidence of circumstances where he believed he waited too long, and where his request was not granted, in his supplemental materials. In both cases the last clause of 6.2.2 appears to be applicable. “Where the manufacturer/remanufacturer's approval cannot be obtained, permission to perform modifications may be granted by an equivalent entity after analysis and approval of an engineer.” Language to which the appellant agreed to in June of last year.
In conclusion, the respondent for the ASC A92 would note that there are numerous sections of A92 standards which contain language including “should” advisory clauses. It is the position of the respondent that this is not unusual in ANSI standards and the ASC A92 should not be required to be excessively specific in these particular clauses. Delay of the implementation of a standard based upon advisory language which has reached the required consensus level while following ASC A92 and ANSI procedures is damaging to the industry and stake holders in general.
Response by,
Joshua Chard, Ph.D.
ASC A92 Chair
Global Rental Co., Inc. – a subsidiary of Altec, Inc.
By Visiting SAIA main website, going to the ANSI page for A92 and clicking the link on the right side that addresses commercial terms in red.
https://www.saiaonline.org/files/SAIA%20Response%20to%20ANSI%20BSR.pdf
Yes, If you are involved with aerial work platforms. If you are materially effected by the standards text you should immediately complete the application and start participating.
Here is a list of the current standards.
- ANSI/SAIA A92.20-2020: Design, Calculations, Safety Requirements and Test Methods for Mobile Elevating Work Platforms (MEWPs)
- ANSI/SAIA A92.22-2020: Safe Use of Mobile Elevating Work Platforms (MEWPs)
- ANSI/SAIA A92.24-2018: Training Requirements for the Use, Operation, Inspection, Testing and Maintenance of Mobile Elevating Work Platforms (MEWPs)
These new standards, which incorporate performance criteria rather than being product-specific, will replace the standards listed below that are currently in place:
- ANSI/SAIA A92.3-2006 (R2014) for Manually Propelled Elevating Aerial Platforms
- ANSI/SAIA A92.5-2006 (R2014) for Boom-Supported Elevating Work Platforms
- ANSI/SAIA A92.6-2006 (R2014) for Self-Propelled Elevating Work Platforms
- ANSI/SAIA A92.8-2006 (R2011) for Vehicle-Mounted Bridge Inspection and Maintenance Devices
Additional standards managed and maintained by the ASC A92 include:
- ANSI/SAIA A92.2-2015 for Vehicle-Mounted Rotating and Elevating Work Platforms
- ANSI/SAIA A92.7-2014 for Airline Ground Support Vehicle-Mounted Vertical Lift Devices
- ANSI/SAIA A92.9-2011 (R2017) for Mast-Climbing Work Platforms
- ANSI/SAIA A92.10-2009 (R2014) for Transport Platforms