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Elevating Work Platforms
Safety Guideline for the Live Performance Industry in Ontario

Disclaimer: This resource has been prepared to help the workplace parties understand some of their obligations under the Occupational Health and Safety Act (OHSA) and regulations. It is not legal advice. It is not intended to replace the OHSA or the regulations. For further information please see full disclaimer.

Introduction

This guideline refers to relevant provisions in the Industrial Establishments Regulation (Reg. 851) if work is being conducted on an elevating work platform (EWP) at an industrial establishment and in the Construction Projects Regulation (O. Reg. 213/91) if work is being conducted on an EWP at a project. This guideline also includes best practices, procedures and information on EWPs for live performance workplaces.

The Construction Projects Regulation applies to all construction projects as defined by the Occupational Health and Safety Act (OHSA). Examples of when the Construction Projects Regulation applies to a live performance include: load-ins or take-ins (fit-ups, set-ups), lighting hangs, load-outs or take-outs (tear-downs and strikes). The Industrial Establishments Regulation applies to all industrial establishments as defined by the OHSA. The requirements in the Industrial Establishments Regulation apply to more predictable, stable, repetitive work activities found in scenery, properties or costume shops, in lighting focus sessions, rehearsals, performances, scene changes, changeovers, etc.

This guideline should be read in conjunction with the Working At Heights and Application of the Industrial and Construction Regulations Safety Guidelines.

Definitions

Note: These definitions are provided for clarity and guidance only and, unless otherwise noted, are not definitions found under the OHSA or its regulations.

Best practice:
A program, process, method, technique, strategy or activity that:
  • has been shown to be effective in the prevention of workplace injury or illness
  • has been implemented, maintained and evaluated
  • is based on current information
  • is of value to, or transferable to, other organizations as an example (for one, the Theatre Alberta, Hazard Assessment Safe Stages Glossary).
Competent person:
Means a person who, is qualified because of knowledge, training and experience to organize the work and its performance, is familiar with this Act and the regulations that apply to the work, and has knowledge of any potential or actual danger to health or safety in the workplace (section 1(1) of the OHSA).
Elevating work platforms (EWP):
Hydraulically, electrically or mechanically controlled devices used to elevate workers or materials. In the live performance industry these include: scissor lifts, articulated boom lifts, individual personnel lifts, self-propelled lifts, manual “push-around” lifts, elevating rolling work platforms, self-propelled elevating work platforms, boom-type elevating work platforms, vehicle-mounted aerial devices and aerial work platforms (definition based on information contained in Working at Heights Guideline; see also section 143(1) of O. Reg. 213/91.
Emergency stop button:
A system designed to limit or avoid damage or hazard to someone or something in an emergency. Most elevating work platforms are equipped with an emergency stop button that is used to immediately disable the EWP from unwanted or accidental operation.
Fall protection:
A method of minimizing the possibility of falling.
Full body harness:
One component of a fall arrest or travel restraint system composed of leg and shoulder strap supports and an upper dorsal suspension assembly that can guide and distribute the impact forces of a fall.
Lanyard:
Flexible line of rope, wire rope, or strap which generally has a connector at each end for connecting the body belt or body harness to a deceleration device, lifeline, or anchorage. (See the Working at Heights Guideline.)
Lifting device:
Means a device that is used to raise or lower any material or object and includes its rails and other supports but does not include a device to which Ontario Regulation 209/01 (Elevating Devices), made under the Technical Standards and Safety Act, 2000, applies.
Outrigger:
Device used to stabilize an elevating work platform.
Travel restraint system:
An assembly of components capable of restricting a worker’s movement on a work surface and preventing the worker from reaching a location from which he or she could fall (Working at Heights Guideline and section 1(1) of O. Reg. 213/91).
Work positioning systems:
Aerial or elevating work platforms, ladders and boatswain’s chairs (Working at Heights Guideline).

Training

  1. The employer shall provide the EWP operator with training and supervision to protect the health and safety of the worker (section 25(2)(a) of the OHSA).
  2. The employer shall acquaint a worker or a person in authority over a worker with any hazard in the use of an EWP and in the handling, storage, use and transport of the EWP (section 25(2)(d) of the OHSA).

General:

  1. Operators must receive information and instruction on how to safely operate the class of EWP that they will be using. Training should include the manufacturer’s instructions.
  2. Periodic training refreshers are recommended to ensure operator competence.
  3. Operators should keep a copy of their proof of training at the workplace, either on their person or at a convenient nearby location.
  4. Employers should keep records of operator and worker training at the workplace.

If the work is being conducted as part of a project:

  1. The Occupational Health and Safety Awareness and Training Regulation (O. Reg. 297/13) requires that employers ensure that workers on construction projects successfully complete a working at heights training program if those workers are required by the Construction Projects Regulation to use specified methods of fall protection (travel restraint system, fall restricting system, fall arrest system, safety net, work belt, or safety belt). The program must be approved by the Chief Prevention Officer (CPO) and must be delivered by a training provider approved by the CPO (sections 6 and 7 of O. Reg. 297/13). Employers must also keep a record of the working at heights training and make it available to an inspector on request (section 10 of O. Reg. 297/13).
  2. An employer must ensure that a worker who may use a fall protection system is adequately trained in its use and given adequate oral and written instructions by a competent person (section 26.2 (1) of O. Reg. 213/91).
  3. Before operating an EWP for the first time, each worker must be given oral and written instruction on the operation and be trained to operate that class of EWP (section 147(1) of O. Reg. 213/91).
  4. EWP instruction and training must include (section 147(2) of O. Reg. 213/91):
    • the manufacturer’s instructions
    • instruction in the load limitations
    • instruction in and a hands-on demonstration of the proper use of all controls, and
    • instruction in the limitations on the kinds of surfaces on which it is designed to be used.
    Note: Training should also include instruction on specific workplace hazards and an evaluated demonstration by the worker of safe operation skills.

If the work is being conducted at an industrial establishment:

  1. Before wearing or using protective equipment or devices, such as fall protection equipment, workers must receive information and instruction in its care and use (section 79 of Reg. 851).
  2. A lifting device must only be operated by a competent person or a worker being instructed who is accompanied by a competent person (section 51(2)(a) of Reg. 851).

Equipment, inspection and maintenance

  1. EWPs provided by the employer must be maintained in good condition (section 25(1)(b) of the OHSA).
  2. Repairs to EWPs should only be done according to manufacturers’ instructions by a manufacturer-approved company.
  3. An EWP that is unsafe to use and may endanger a worker must be locked out of service by disabling the device and marking it with a tag that describes the problem and indicates that the equipment is not to be used.

If the work is being conducted as part of a project:

  1. An EWP may only be used if a professional engineer has certified in writing that it complies with the National Standards of Canada standard applicable to that type of EWP (section 144(4) of O. Reg. 213/91).
  2. Do not modify an EWP in any way unless permitted by manufacturer and certified by an engineer.
  3. An operator’s manual for an EWP must be kept with it (section 149 of O. Reg. 213/91).
  4. Follow manufacturer’s instructions for refueling or charging the battery. Use appropriate personal protective equipment during these activities.
  5. For each EWP owned, the owner must keep a permanent record of all inspections, tests, repairs, modifications and maintenance performed on it (section 145(2) of O. Reg. 213/91).

If the work is being conducted at an industrial establishment:

  1. EWPs must be inspected at least annually, and maintained according to manufacturers’ instructions by a manufacturer-approved company (section 51 of Reg. 851).

Procedures

Pre-use inspection

  1. The EWP should be inspected each day before use in accordance with manufacturer’s instructions.
  2. The inspection checklist should be completed and should include a visual inspection, a functional test and daily maintenance checks.
  3. This information should be kept on file by the supervisor for six months or longer.
  4. Any defects must be reported to the employer or supervisor immediately and corrected, before the equipment is operated (section 28(1)(d) of the OHSA).

Personal protective equipment (PPE)

  1. If on a project and workers are on the platform when it is moved, they must be protected from ejection by being attached to an adequate anchorage point on the EWP by a method of fall protection (section 148(1)(d) of O. Reg. 213/91).
  2. If at an industrial establishment, workers who are exposed to a hazard of falling more than three metres must be protected by a fall arrest system (section 85 of Reg. 851).
  3. Head protection must be worn as applicable under the appropriate regulation. Refer to the Application of Industrial and Construction Regulations Guideline for details.

Work area survey

  1. Before operating the EWP, the operator should consider the job to be performed and should evaluate the work area for potential hazards such as debris, overhead lines and obstructions, unguarded openings and stage edges or hazards created by other conditions (such as darkness or loud sounds that impede communication).
  2. An EWP should only be operated on a firm, stable, horizontal and level surface unless permitted by the manufacturer (refer to the manufacturer's instructions).
  3. An EWP should only be used on an operating surface that can adequately support the weight of the EWP, workers, material, equipment and tools (section 25(1)(e) of the OHSA).
  4. EWPs are not intended for use near overhead power lines. When it is necessary for equipment to be operated near overhead power lines, the EWP must not encroach on the minimum approach distances as prescribed in section 188 of O. Reg. 213/91and section 60 of Reg. 851, as applicable. If on a project, written measures and procedures must be in place.
  5. An EWP should not be operated in windy conditions. For safe wind speeds, refer to the manufacturer’s instructions.

Elevating work platform operation

  1. Follow all operating instructions issued by the manufacturer at all times.
  2. Ensure that the load of workers, materials, equipment and/or tools on the platform does not exceed the manufacturer’s rated capacity for the EWP (section 51(1)(c) of Reg. 851). 
  3. Secure loads to the platform while moving to prevent tools, materials, equipment and other items from falling from the platform. Ensure hand tools and loose items are affixed to the worker’s body or platform (section 45 of Reg. 851).
  4. Carry materials in accordance with the manufacturer’s instructions. Ensure any load to be carried fits within the guardrails. Ensure there is no overhang of materials beyond the distances allowed by the manufacturer’s instructions when operating the platform.
  5. When operating an EWP, another worker should be present on the ground at all times in case of an emergency and to ensure the safe movement of the platform.  The worker on the ground should be trained on how to bring the platform down in an emergency, in accordance with the manufacturer’s instructions.  A communication system and a written rescue plan should be in place.
  6. For EWPs with outriggers: do not raise the platform unless all outriggers are correctly installed in accordance with manufacturer’s instructions.
  7. The operator should always control the EWP.  No ground-operated controls should be engaged without the permission of the worker at height, except in an emergency.
  8. Move or reposition raised EWPs in accordance with the manufacturer’s instructions for the specific EWP. It is recommended that a self-propelled EWP should be lowered for continuous travel greater than 6m (20’) or when navigating hazards (for example, transitions in floor surfaces or expansion joints).
  9. When an EWP is repositioned, a worker should be present on the ground to ensure the path of travel is clear of obstructions. The EWP should not be moved until the operator has determined by visual inspection that the direction of intended movement is clear of hazards, obstructions and other workers.
  10. When moving an EWP, limit the travel speed according to the conditions.
  11. Prevent ropes, electrical cords, hoses, etc. from becoming entangled when the platform is being elevated or moved.
  12. Once in position, disable an EWP against unwanted operation by engaging the emergency stop button(s) or turning it off.
  13. Do not override safety features. When any of the safety devices are inoperable, the EWP should be locked out of service so it cannot be operated.
  14. Do not anchor or attach an EWP to a permanent structure while working at height.
  15. Do not subject an EWP to a horizontal force or side load. This includes windy conditions, pushing or pulling from the platform, hanging objects over the side or leaning objects against it.
  16. Do not use an EWP as a crane unless specifically designed for that use.
  17. Do not exit a raised platform except in accordance with the manufacturer’s instructions.
  18. Do not climb, sit or stand on, hang from or lean out over the guardrails on the platform.
  19. Do not modify an EWP in any way unless permitted by manufacturer and certified by an engineer. This includes adding planks or ladders to an elevating work platform to gain additional height.
  20. Before leaving the EWP unattended, lock or otherwise prevent its unauthorized use.

Safe shutdown and storage

  1. Move the EWP to a suitable parking area.
  2. Place the platform in the stowed position.
  3. Shut off the EWP and lock it or otherwise prevent its unauthorized use.

References and resources

  1. Elevating Work Platform Safety in Construction
    Ministry of Labour
  2. Elevating Work Platforms, Construction Health & Safety Manual [PDF]
    Infrastructure Health & Safety Association

ISBN 978-1-4868-0007-0  (HTML)

Disclaimer: This web resource has been prepared to assist the workplace parties in understanding some of their obligations under the Occupational Health and Safety Act (OHSA) and the regulations. It is not intended to replace the OHSA or the regulations and reference should always be made to the official version of the legislation.

It is the responsibility of the workplace parties to ensure compliance with the legislation. This web resource does not constitute legal advice. If you require assistance with respect to the interpretation of the legislation and its potential application in specific circumstances, please contact your legal counsel.

While this web resource will also be available to Ministry of Labour inspectors, they will apply and enforce the OHSA and its regulations based on the facts as they may find them in the workplace. This web resource does not affect their enforcement discretion in any way.