OSHA Seeks Public Comments on Aerial Lift Modification Requirements

The Occupational Safety and Health Administration (OSHA) recently published a notice in the Federal Register announcing its intent to renew Office of Management and Budget (OMB) approval for existing recordkeeping requirements related to aerial lifts.

While this notice does not introduce new regulatory requirements, it serves as an important reminder of a commonly overlooked compliance issue: documentation of manufacturer approval for aerial lift modifications.

What Is OSHA Requesting?

OSHA is seeking public comments on the continued approval of information collection requirements associated with aerial lifts. These requirements stem from the existing standards that prohibit modifications to aerial lifts unless the changes are approved by the manufacturer or equivalent authority.

29 CFR 1910.67(b)(2) states that “aerial lifts may be ‘field modified’ for uses other than those intended by the manufacturer only if such modifications have been certified in writing by the manufacturer or by any other equivalent entity…”

In practice, many facilities unintentionally fall out of compliance in this area. Common examples include:

• Adding tool trays, attachments, or welding racks
• Modifying guardrails or platforms
• Installing aftermarket components without manufacturer review
• Making field adjustments to improve usability or efficiency

Even minor changes can be considered a modification under OSHA standards if they affect the structural integrity or safe operation of the equipment.

Without proper approval and documentation, modified aerial lifts may no longer meet their original design specifications. This can introduce safety risks and expose employers to potential citations and penalties.

Why Does It Matter if the Rules Aren’t Changing?

Even though this notice doesn’t introduce any new requirements, it highlights an existing obligation that is frequently missed. OSHA’s request for comments is part of the federal process to evaluate whether these recordkeeping requirements remain necessary, practical, and not overly burdensome.

For employers, this presents an opportunity to stay informed on regulatory expectations, provide feedback on real-world challenges, and identify and correct compliance gaps before they result in citations.

If you are interested in submitting a comment, you must do so by the April 13 deadline.

How Walden Can Help

If you need assistance evaluating your compliance with OSHA or other standards, Walden can help. Our team of EHS Specialists can:

• Verify whether any aerial lifts have been modified
• Obtain manufacturer approval for aerial lift modifications
• Maintain documentation of approvals
• Train employees to avoid making unauthorized modifications

Contact us at 860-846-4069 to speak with our knowledgeable safety team today.